Sanders v. Grimes

CourtDistrict Court, S.D. Illinois
DecidedJuly 25, 2025
Docket3:25-cv-01010
StatusUnknown

This text of Sanders v. Grimes (Sanders v. Grimes) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanders v. Grimes, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

CORDELL SANDERS, ) R41346, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-1010-DWD ) MICAH GRIMES, ) WHITE, ) ) Defendants. )

MEMORANDUM & ORDER

DUGAN, District Judge:

Plaintiff Cordell Sanders, an inmate of the Illinois Department of Corrections (IDOC) currently detained at Menard Correctional Center, brings this civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights at Lawrence Correctional Center (Lawrence). Specifically, Plaintiff alleges that the Defendants used excessive force when placing him in a segregation cell, and their conduct was retaliation for a grievance Plaintiff filed against Sanders a year earlier. The Complaint (Doc. 1) is now before the Court for preliminary review pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a)-(b). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations of the pro se complaint are to be liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). THE COMPLAINT

Plaintiff alleges that in June of 2023 when he was housed in the infirmary at Lawrence, Defendant Grimes confiscated a tablet charger for no reason. He grieved the issue, and when he was unsatisfied with the responses at the prison level, in April of 2024, he appealed to the Administrative Review Board (ARB). Plaintiff alleges that just 4 days after the grievance arrived at the ARB, on April 22, 2024, he was taken to solitary

confinement for an unrelated issue. (Doc. 1 at 3). Upon arrival to the seg building, Defendant Grimes gave him an angry look, and Grimes and White then shackled him behind his back to escort him to his cell. Plaintiff alleges that after he was inside of the cell, White misused the ankle shackles by attacking them to his handcuffs and using the two sets of restraints to

violently yank his arms and hands thru the hatch on his cell door. (Doc. 1 at 3). In the process, his right index finger struck the hatch, and he sustained a half-inch cut that immediately bled. With his arms thru the hatch, Grimes and White began to bend and bang his arms against the door, causing bruising. With his arms still thru the door, they deployed an entire can of pepper spray onto Plaintiff’s jumpsuit, without warning. He

alleges White also called him a monkey during the encounter. Plaintiff alleges that the entire interaction was an act of retaliation for the grievance against Grimes about the tablet charger. (Doc. 1 at 4). He further alleges that in an attempt to cover up the retaliation, Grimes issued a false disciplinary ticket claiming that Plaintiff grabbed White’s finger during the interaction on April 22, 2024. Plaintiff alleges that he challenged the disciplinary ticket before the ARB, and the ARB found that he had

not committed the injury with assault offense alleged in the ticket. Plaintiff attached supporting documents. He included a medical record from April 22, 2024, that indicated he was seen by a nurse for a .5 inch scrape on his finger and to decontaminate from “getting sprayed.” (Doc. 1 at 7). An ARB form indicated that the disciplinary assault charge was reduced from assault with injury to plain assault. (Doc. 1 at 8). Plaintiff also included a few other grievance documents. Plaintiff seeks monetary

compensation and indicates a desire to proceed on First and Eighth Amendment claims. Based on the allegations in the Complaint the Court designates the following counts: Claim 1: Eighth Amendment excessive force claim against Defendants Grimes and White for their alleged conduct on April 22, 2024, when placing Plaintiff in his segregation cell;

Claim 2: First Amendment retaliation claim against Defendants Grimes and White for utilizing excessive force in response to Plaintiff’s April 18, 2024, grievance appeal to the ARB concerning his 2023 interaction with Grimes over his tablet charger.

The parties and the Court will use these designations in all future pleadings and orders unless otherwise directed by a judicial officer of this Court. Any claim that is mentioned in the Complaint but not addressed in this Order is considered dismissed without prejudice as inadequately pled under Twombly. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim that is plausible on its face”). DISCUSSION An Eighth Amendment excessive force claim requires an inquiry into “whether force was applied in a good-faith effort to maintain or restore discipline, or [whether it

was] applied maliciously and sadistically to cause harm.” Hudson v. McMillian, 503 U.S. 1, 7 (1992). The “core judicial inquiry” for an excessive force claim not the severity of the injury, but whether the force used was ‘malicious and sadistic.’ Wilkins v. Gaddy, 559 U.S. 34, 37 (2010). Here, Plaintiff contends the Defendants used force that was entirely unnecessary to place him in his cell. Specifically, he claims that once he was within the

cell, Defendants Grimes and White removed his ankle shackles and then attached the chain to his handcuffs so that his arms could be pulled through the hatch of his door. He also alleges that they deployed an entire can of pepper spray while his hands were held thru the hatch, and he was inside of the cell. Although his injury is very minor, he alleges the force was used completely without justification and was done as an act of retaliation

for grievance activity. These allegations are sufficient to proceed beyond initial review. Plaintiff also alleges that Defendants Grimes and White acted in retaliation for a grievance that he appealed to the ARB about Grimes’ past conduct, just days before the alleged excessive force encounter on April 22, 2024. Plaintiff claims that Grimes referenced the grievance during the incident of force, and White called him a monkey. A

successful claim for First Amendment retaliation requires that a plaintiff show, “(1) he engaged in activity protected by the First Amendment; (2) he suffered a deprivation that would likely deter First Amendment activity in the future; and (3) the First Amendment activity was ‘at least a motivating factor’ in the Defendants’ decision to take the retaliatory action.” Bridges v. Gilbert, 557 F.3d 541, 546 (7th Cir. 2009) (quoting Woodruff v. Mason, 542 F.3d 545, 551 (7th Cir. 2008)). An inmate may meet the prima facie showing

by offering direct or circumstantial evidence that the defendant’s actions were motivated by retaliation. See e.g., Kidwell v.

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Related

Wilkins v. Gaddy
559 U.S. 34 (Supreme Court, 2010)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Kidwell v. Eisenhauer
679 F.3d 957 (Seventh Circuit, 2012)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Bridges v. Gilbert
557 F.3d 541 (Seventh Circuit, 2009)
Woodruff v. Mason
542 F.3d 545 (Seventh Circuit, 2008)

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Bluebook (online)
Sanders v. Grimes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanders-v-grimes-ilsd-2025.