Ryan A. Swank v. Martin Edwards, et al.

CourtDistrict Court, C.D. Illinois
DecidedOctober 21, 2025
Docket4:25-cv-04171
StatusUnknown

This text of Ryan A. Swank v. Martin Edwards, et al. (Ryan A. Swank v. Martin Edwards, et al.) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ryan A. Swank v. Martin Edwards, et al., (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

RYAN A. SWANK, ) ) Plaintiff, ) ) v. ) 4:25-cv-04171-SEM-DJQ ) MARTIN EDWARDS, et al., ) ) Defendants.

ORDER Plaintiff, proceeding pro se and presently incarcerated at Robbinson Correctional Center, alleges Defendants violated his Fourteenth Amendment rights through objectively unreasonable conditions of confinement at the Warren County Jail. The Court must “screen” Plaintiff’s complaint to determine if Plaintiff states a claim for relief. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. The Court accepts the factual allegations as true, liberally construing them in the plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (7th Cir. 2013). Conclusory statements and labels are insufficient—the facts alleged must “state a claim for relief that is plausible on its face.” Alexander v. United States, 721 F.3d 418, 422

(7th Cir. 2013). A. Facts Plaintiff names as Defendants Sherrif Martin Edwards, John

Doe Maintenance Personnel and Deputies Ian Haire and Ray Hogue. A shower in the jail had a loose drain cover. The drain itself was also clogged. When the shower was in use, the standing water

would conceal the easily displaced drain cover. All Defendants knew of this dangerous condition and, despite that knowledge, did not take any action to effect repair.

On October 3, 2023, at about 10:45, Plaintiff was using the shower. The shower floor flooded, and the drain cover displaced. As Plaintiff left the shower his foot was trapped in the concealed

hazard and he fell, sustaining a concussion and other injuries for which he was treated at a local emergency room. He continues to suffer lasting effects of the fall. B. Analysis

At relevant times, Plaintiff was a pretrial detainee. As a pretrial detainee Plaintiff must allege that the conditions under which he was detained were “objectively unreasonable,” a standard higher than mere negligence, but lower than deliberate indifference as

applied in Eighth Amendment circumstances for convicted prisoners. Miranda v. County of Lake, 900 F.3d 335, 352 (7th Cir. 2018). Caselaw is more developed regarding hazardous conditions

in prisons, and claims by pretrial detainees and convicted prisoners have until recently been assessed under the same standard. The Court thus describes the general contours of the law regarding

hazardous conditions with some reference to prison cases while in assessing Plaintiff’s claims applies the current Fourteenth Amendment standard of objective unreasonableness.

Officials must “ensure ‘reasonable safety,’ not that they protect against all risks.” Estate of Simpson v. Gorbett, 863 F.3d 740, 746 (7th Cir. 2017) (quoting Farmer v. Brennan, 511 U.S. 825, 844–45

(1994)). Prisoners are protected from the unnecessary infliction of pain caused by hazardous prison conditions. Pyles v. Fahim, 771 F.3d 403, 408 (7th Cir. 2014). A prison condition is hazardous when it “poses an unreasonable peril.” Anderson v. Morrison, 835

F.3d 681, 683 (7th Cir. 2016). When risk of injury is small and the condition is necessarily unavoidable, such as a wet shower floor, the Seventh Circuit has held that the condition does not pose a sufficient risk of harm. See Pyles, 771 F.3d at 410 (“Federal courts

consistently have adopted the view that slippery surfaces and shower floors in prisons, without more, cannot constitute a hazardous condition of confinement.”); see also Hardin v. Baldwin,

770 F. App’x 289, 290 (7th Cir. 2019) (“The condition that [the plaintiff] identifies is the uneven sidewalk, but the risk of tripping there is no worse than the risk present on slippery floors in prison

showers.”). However, when risk of injury is great and the hazardous condition is avoidable, such as prison officials forcing inmates with

their hands cuffed behind their backs to navigate stairs slicked with milk and cluttered with garbage, the Seventh Circuit has held that the condition poses a sufficient risk of harm to state a

constitutional claim. Anderson, 835 F.3d at 683 (7th Cir. 2016); see also Perkins v. Pfister, 711 F. App’x 335, 337 (7th Cir. 2017) (discussing Pyles and Anderson and finding that officials occasionally forcing inmates to traverse stairs with hands cuffed

behind their backs is not alone enough to state a constitutional claim). An official’s “duty to protect an inmate from harm arises because the state has placed him ‘under a regime that incapacitates

[him] to exercise ordinary responsibility for his own welfare.’” Christopher v. Buss, 384 F.3d 879, 882–83 (7th Cir. 2004) (quoting County of Sacramento v. Lewis, 523 U.S. 833, 851 (1998)). An

inmate will fail to state a claim for failure to protect where the inmate is able “to exercise responsibility for his own welfare.” Christopher, 384 F.3d at 883.

Here, Plaintiff’s allegations are more like the situation in Anderson, and less like the situation in Pyles. The clogged drain and loose drain grate each posed a hazard. Both were conditions

that could have been easily avoided with proper maintenance. Plaintiff alleges each Defendant knew of these hazards and intentionally failed to address them. Because the open hole in the

floor was concealed by the clogged drain, it is plausible that, even with reasonable care, Plaintiff was unable to ensure his own safety. These allegations state a Fourteenth Amendment claim against each named Defendant.

IT IS THEREFORE ORDERED: 1. Pursuant to its merit review of the Complaint under 28 U.S.C. § 1915A, the Court finds Plaintiff states a Fourteenth Amendment claim for unconstitutional conditions of confinement against each of the named Defendants. Any additional claims shall not be included in the case, except at the Court's discretion on motion by a party for good cause shown or pursuant to Federal Rule of Civil Procedure 15.

2. This case is now in the process of service. Plaintiff is advised to wait until counsel has appeared for the named Defendants before filing any motions, to give notice to said Defendants and an opportunity to respond to those motions. Motions filed before counsel has filed an appearance on behalf of Defendants will generally be denied as premature. Plaintiff need not submit any evidence to the Court at this time, unless otherwise directed by the Court.

3. The Court will attempt service on Defendants by mailing each Defendant a waiver of service. Defendants have 60 days from the date the waiver is sent to file an answer. If Defendants have not filed answers or appeared through counsel within 90 days of the entry of this order, Plaintiff may file a motion requesting the status of service.

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Related

County of Sacramento v. Lewis
523 U.S. 833 (Supreme Court, 1998)
Dennis W. Christopher v. Edward Buss
384 F.3d 879 (Seventh Circuit, 2004)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Christopher Pyles v. Magid Fahim
771 F.3d 403 (Seventh Circuit, 2014)
Alvin T. Perkins, Jr. v. Randy Pfister
711 F. App'x 335 (Seventh Circuit, 2017)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Anderson v. Morrison
835 F.3d 681 (Seventh Circuit, 2016)
Estate of Simpson v. Gorbett
863 F.3d 740 (Seventh Circuit, 2017)

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