Smith v. Hughes

CourtDistrict Court, S.D. Illinois
DecidedJanuary 31, 2025
Docket3:24-cv-02349
StatusUnknown

This text of Smith v. Hughes (Smith v. Hughes) 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
Smith v. Hughes, (S.D. Ill. 2025).

Opinion

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

THOMAS SMITH,

Plaintiff, Case No. 24-cv-02349-SPM v.

LATOYA HUGHES, DARREN GALLOWAY, KARL BRADFORD, and JACOB HORN,

Defendants.

MEMORANDUM AND ORDER

MCGLYNN, District Judge: Plaintiff Thomas Smith, an inmate of the Illinois Department of Corrections who is currently incarcerated at Pinckneyville Correctional Center, brings this civil action pursuant to 42 U.S.C. § 1983 for violations of his constitutional rights that occurred at Shawnee Correctional Center. The First Amended Complaint is now before the Court for preliminary review pursuant to 28 U.S.C. § 1915A. Under Section 1915A, any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or requests money damages from a defendant who by law is immune from such relief must be dismissed. See 28 U.S.C. § 1915A(b). THE FIRST AMENDED COMPLAINT Plaintiff alleges that in February 2023, while housed at Shawnee Correctional Center, he was placed in a cell with a broken window. (Doc. 11, p. 3). At the time, there was a snowstorm, and the outside temperature was well below freezing. The cell had approximately a foot of snow in the corner that had blown in through the broken window. Plaintiff tried to keep warm by layering his clothing and staying under blankets, but he was freezing. His hands and feet were numb and stinging with pain. After three or four days, Plaintiff filed an emergency grievance about the conditions of his cell. Defendant Warden Darren Galloway denied the grievance. (Id.). After remaining in the cell for another five days, Plaintiff could not “physically or mentally

handle being frozen” and so he “refused housing by going on hunger strike.” (Doc. 11, p. 3). Plaintiff was placed in segregation, where he continued to be subjected to cold temperatures, as the heaters in the segregation unit were not working. Plaintiff wrote a letter to Defendant Director Latoya Hughes seeking help but did not receive a response. Eventually, Plaintiff states he came to an agreement with mental health staff. He quit the hunger strike and was moved to a unit with functioning heaters and no broken windows. (Id.). On October 31, 2023, Plaintiff was instructed to move to a new cell in a housing unit with broken heaters and windows. (Doc. 11, p. 3). At the time, the temperatures outside were dropping. Plaintiff did not want to move back into a freezing cell, and so he refused housing and again went on a hunger strike. Plaintiff was issued a disciplinary ticket for disobeying a direct order and placed

in segregation. (Id.). While on his hunger strike, Plaintiff states he met with Warden Galloway on several occasions. (Id. at p. 4). During their first interaction, Plaintiff told Galloway that he was on a hunger strike because he did not want to be moved into a freezing cell with a broken window. Galloway told Plaintiff, “You don’t get to choose where you live[,] this is prison not the Hilton and since you’re not eating, I guess you’ll just be cold and hungry.” Plaintiff wrote a grievance and another letter to Director Hughes. Again, he did not receive a response. (Id.). On November 2, 2023, Plaintiff met with Defendant Intelligence Officer Horn about why he was on a hunger strike. (Doc. 11, p. 4). Plaintiff explained the situation, and Horn “strongly advised that [Plaintiff] come off the hunger strike.” Plaintiff refused unless he was guaranteed to

be placed in a cell with a working window and heater. Horn responded, “you’re going to regret that answer.” (Id.). On November 4, 2023, Plaintiff received a false disciplinary ticket, written by Horn, for making threats about staff on a phone call with family members. (Doc. 11, p. 4). Plaintiff was charged with dangerous communications and threats or intimidation. (Id.).

On November 7, 2023, Plaintiff had a hearing before the Adjustment Committee on the charges of disobeying a direct order. (Doc. 11, p. 4). The Adjustment Committee was chaired by Defendant Bradford. Prior to the hearing, Plaintiff states he did not receive a copy of the ticket and was not allowed to call any witnesses. (Id.). Plaintiff was found guilty and sentenced to fourteen days in segregation, thirty days of C-grade status, and a disciplinary transfer. (Id. at p. 5). Plaintiff’s disciplinary hearing for the charges of dangerous communications and threats or intimidation was held before Bradford on November 11, 2023. (Doc. 11, p. 5). Based on no evidence, Plaintiff was found guilty. He was sanctioned with an additional fourteen days in segregation, an additional thirty days of C-grade status, and a disciplinary transfer. (Id.). On November 18, 2023, Plaintiff again spoke to Warden Galloway. (Doc. 11, p. 5).

Plaintiff told Galloway that he was still on a hunger strike because staff was attempting to place him in a cell without a working window and no heat. Plaintiff also told Galloway that Bradford had not followed proper procedures during his disciplinary hearings. Galloway did not investigate any of Plaintiff’s claims. Plaintiff was transferred to Pinckneyville Correctional Center, a higher security prison. (Id.). Plaintiff filed grievances regarding his disciplinary hearings, and the Administrative Review Board overturned the findings of guilt and expunged both disciplinary tickets from Plaintiff’s record. (Doc. 11, p. 6). PRELIMINARY DISMISSAL

Plaintiff states that he is suing defendants in their individual and official capacity. (Doc. 11, p. 1-2). Plaintiff, however, is only seeking monetary damages and so his official capacity claims are dismissed with prejudice. See Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 (1989); Wynn v. Southward, 251 F.3d 588, 592 (7th Cir. 2001). The Court also dismisses all claims against Director Hughes. Plaintiff claims that he wrote

two letters to Hughes about the cold conditions of his cells putting her on notice of his alleged unconstitutional conditions. (Doc. 11, p. 1, 3, 4). But Plaintiff cannot recover damages under Section 1983 based on the theory that because he wrote Hughes letters, she is personally liable for harm caused by the conditions of his cell at Shawnee Correctional Center. Courtney v. Devore, 595 F. App’x 618, 620 (7th Cir. 2014) (upper-level officials “are ordinarily not personally liable for decisions made by subordinates, even if they receive a letter complaining about those decisions and do not intervene.” (citing Burks v. Raemisch, 555 F.3d 592, 595–96 (7th Cir. 2009))). Accordingly, Plaintiff has failed to state a viable claim against Hughes. DISCUSSION Based on the allegations in the First Amended Complaint, the Court designates the

following counts: Count 1: Eighth Amendment claim against Galloway, Braford, and Horn for failing to provide Plaintiff with constitutional conditions of confinement in 2023.

Count 2: First Amendment claim against Horn for issuing Plaintiff a false disciplinary ticket in retaliation for Plaintiff declaring a hunger strike and requesting to be placed in a cell with functioning heat and without a broken window.

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Smith v. Hughes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-hughes-ilsd-2025.