Sealy v. Partain

CourtDistrict Court, S.D. Illinois
DecidedSeptember 21, 2023
Docket3:22-cv-02349
StatusUnknown

This text of Sealy v. Partain (Sealy v. Partain) 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
Sealy v. Partain, (S.D. Ill. 2023).

Opinion

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

AARON SEALY,

Plaintiff,

v. Case No. 22-CV-02349-SPM

CHASE PARTAIN, et al.,

Defendants.

MEMORANDUM AND ORDER

McGLYNN, District Judge:

Plaintiff Aaron Sealy filed a Complaint (Doc. 1) and was subsequently granted leave to file an amended complaint (Doc. 22). On January 25, 2023, Sealy filed an Amended Complaint alleging violations of 42 U.S.C. § 1983, Willful and Wanton Conduct, and Indemnification against Defendants Chase Partain, City of Mcleansboro, D. Elliot, Hamilton County Sheriff’s Office, and Hamilton County. (Doc. 25). Pending before the Court is Defendants D. Elliot, Hamilton County Sheriff’s Office, and Hamilton County’s (“Defendants”) Motion to Dismiss the Complaint and Memorandum in Support (Docs. 27, 28). Sealy filed a Response in Opposition to the Motion (Doc. 30). For the reasons set forth below, the Motion is GRANTED in part and DENIED in part. FACTUAL BACKGROUND On October 19, 2021, Sealy was arrested by Partain. (Doc. 25). Elliot subsequently arrived to assist Partain with the arrest. (Id.). Sealy was repeatedly searched, and no weapons were found. (Id.). Sealy was then transported to Hamilton County Sheriff’s Office where he was handcuffed to a wall and seated in a wooden chair. (Id.). At approximately 12:17 AM on October 20, 2021, Plaintiff freed his restraints from the wall. (Id.). Sealy then procured a fire extinguisher and proceeded to take a step back and spray the contents of the extinguisher (powdered

chemicals), hitting both Partain and Elliot while they were approximately 15-20 feet away. (Id.). Both Partain and Elliot unholstered their firearms and discharged three rounds at Sealy. (Id.). One of the rounds fired by either Partain or Elliot struck Sealy in the abdomen. (Id.). LEGAL STANDARD In analyzing a motion to dismiss for failure to state a claim filed pursuant to

Federal Rule of Civil Procedure 12(b)(6), this Court must determine whether or not the complaint contains “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Court of Appeals for the Seventh Circuit has explained that “‘[p]lausibility’ is not a synonym for ‘probability’ in this context, but it asks for ‘more than a sheer possibility that a defendant has acted unlawfully.’” Bible v. United Student Aid Funds, Inc., 799 F.3d

633, 639 (7th Cir. 2015) (quoting Olson v. Champaign County, 784 F.3d 1093, 1099 (7th Cir. 2015)). “While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations . . . [the] [f]actual allegations must be enough to raise a right to relief above the speculative level . . . .” Twombly, 550 U.S. at 555. District courts are required by the Court of Appeals for the Seventh Circuit to review the facts and arguments in Rule 12(b)(6) motions “in the light most favorable to the plaintiff, accepting as true all well-pleaded facts alleged and drawing all possible inferences in her favor.” Tamayo v. Blagojevich, 526 F.3d 1074, 1081 (7th Cir. 2008). “The purpose of a motion to dismiss is to test the sufficiency of the

complaint, not to decide the merits.” Gibson v. City of Chicago, 910 F.2d 1510, 1520 (7th Cir. 1990). ANALYSIS A plaintiff may not recover damages for “harm caused by actions whose unlawfulness would render a conviction or sentence invalid” under § 1983 unless the plaintiff has proven “that the conviction or sentence has been reversed on direct

appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus.” Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). Thus, a claim is barred where “a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence.” McCann v. Neilsen, 466 F.3d 619, 621 (7th Cir. 2006) (quoting Heck, 512 U.S. at 487). However, a § 1983 claim challenging the reasonableness of force used “may be litigated without transgressing Heck . . .”

even though “[p]ublic officials who use force reasonably necessary to subdue an aggressor are not liable on the merits.” Gilbert v. Cook, 512 F.3d 899, 901 (7th Cir. 2008) (citing VanGlider v. Baker, 435 F.3d 689, 692 (7th Cir. 2006)). When assessing reasonableness of force the Supreme Court has held that “if the suspect threatens the officer with a weapon or there is probable cause to believe that he has committed a crime involving the infliction or threatened infliction of serious physical harm, deadly force may be used . . ..” See Tennessee v. Garner, 471 U.S. 1, 11 (1985). Defendants argued that Sealy’s claims are barred by Heck given that Sealy plead guilty to aggravated battery of a police officer in violation of 720 ILCS 5/12-

3.05(d)(4) arising from the same operative facts as this claim. (Doc. 28, p. 9). Sealy argued that Heck does not bar his claim because the allegations in his complaint do not necessarily imply the invalidity of his convictions for aggravated battery. (Doc. 30, p. 6). Sealy admitted at his plea that he sprayed the powder chemicals in both Partain and Elliot’s “eyes, face and nose” which resulted in difficulty seeing and breathing for a period of time after. (Doc. 28-4). Such an admission runs counter to

Sealy’s factual allegation in his Complaint that “[a]t the time Defendants Partain and Elliot fired their service weapons at Plaintiff, Plaintiff did not pose an imminent threat of death or great bodily harm to any individual.” (Doc. 25). Thus, Sealy’s Complaint would call in to question the factual basis of his plea and thus necessarily imply the invalidity of his conviction. Further, Sealy’s Complaint states that “[a]fter spraying the fire extinguisher at Defendants, Plaintiff made no attempt to advance on Defendants and gave no

indication he would use the fire extinguisher in such a manner to cause death or great bodily harm to any individual. Plaintiff also made no attempt to flee the Hamilton Count Sheriff’s Office.” (Id.). By qualifying the assertion that he did not use the fire extinguisher in such a manner to cause death or great bodily harm to any individual with the prefatory phrase “after spraying the fire extinguisher” Sealy impliedly admited that he did use the fire extinguisher in such a manner by discharging it. Therefore, Sealy’s claims against Defendants cannot survive as the allegations therein demonstrate that under Garner the officer’s conduct was reasonable given the circumstances. See Garner, 471 U.S. at 11. Accordingly, Count II of Sealy’s Complaint must be dismissed.

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Related

Tennessee v. Garner
471 U.S. 1 (Supreme Court, 1985)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Tamayo v. Blagojevich
526 F.3d 1074 (Seventh Circuit, 2008)
Gilbert v. Cook
512 F.3d 899 (Seventh Circuit, 2008)
Ronald Olson v. Champaign County, Illinois
784 F.3d 1093 (Seventh Circuit, 2015)
Bryana Bible v. United Student Aid Funds, Inc.
799 F.3d 633 (Seventh Circuit, 2015)
McCann, Patrick J. v. Neilsen, Ken
466 F.3d 619 (Seventh Circuit, 2006)
Gibson v. City of Chicago
910 F.2d 1510 (Seventh Circuit, 1990)

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Sealy v. Partain, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sealy-v-partain-ilsd-2023.