Tate v. Hughes

CourtDistrict Court, S.D. Illinois
DecidedSeptember 2, 2025
Docket3:23-cv-03493
StatusUnknown

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

Opinion

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

JAMES TATE,

Plaintiff, Case No. 23-cv-03493-SPM v.

SYDELLE FULK,

Defendant.

MEMORANDUM AND ORDER

MCGLYNN, District Judge: Plaintiff James Tate initiated this action pursuant to 42 U.S.C. § 1983 while an inmate of the Illinois Department of Corrections (IDOC) alleging violations of his constitutional rights. In the First Amended Complaint, Plaintiff alleges that although he was designated as seriously mentally ill and referred to a residential housing unit, on June 7, 2023, he was transferred to Pinckneyville Correctional Center (Pinckneyville) and placed in general population. While at Pinckneyville, Plaintiff was in a depressed state of mind and had thoughts of hurting himself. The timeline of events is not entirely clear, but at some point, he was taken to the health care unit and treated by Defendant Mental Health Professional Sydelle Fulk, who told him he was weak and that if he cut himself, he should make sure to “hit [his] A C so [he] could bleed out and then [she] would tell the nurses [he was] ready to receive medical attentions.” (Doc. 37-3, p. 2). A few days after his transfer, Plaintiff was involved in a physical fight with his cellmate and placed in segregation. While, in segregation he attempted suicide by cutting his arms and was taken to the health care unit. Plaintiff was seen again by Defendant Fulk, who told Plaintiff he would not receive medical attention for his injuries. Fulk not only denied Plaintiff medical treatment but also harassed him by making racist remarks and telling him to kill himself. (Id. at p. 5). Fulk then placed Plaintiff on crisis watch without providing him medical care. Following a merit review of the First Amended Complaint pursuant to 28 U.S.C. § 1915A, Plaintiff is currently proceeding on the following claims:

Count 2: Eighth Amendment deliberate indifference claim against Fulk for denying Plaintiff treatment for his mental and physical health.

Count 3: Fourteenth Amendment equal protection claim against Fulk.

(Doc. 41). This matter is before the Court on a motion for summary judgment on the issue of exhaustion filed by Defendant Sydelle Fulk. (Doc. 55). Plaintiff has filed responses in opposition. (Doc. 61, 63, 65, 67). For the following reasons, the motion for summary judgment will be granted. LEGAL STANDARDS Summary judgment is proper only if the moving party can demonstrate “that there is no genuine issue as to any material fact and the movant is entitled to judgment as a matter of law.” See FED. R. CIV. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). In determining a summary judgment motion, the Court views the facts in the light most favorable to, and draws all reasonable inferences in favor of, the nonmoving party. Apex Digital, Inc. v. Sears, Roebuck & Co., 735 F.3d 962, 965 (7th Cir. 2013) (citation omitted). II. Exhaustion of Administrative Remedies Lawsuits filed by inmates are governed by the provisions of the Prison Litigation Reform Act (“PLRA”). 42 U.S.C. § 1997e(a). The PLRA states, in pertinent part, that “no action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” Id. The Seventh Circuit requires strict adherence to the PLRA’s exhaustion requirement. Dole v. Chandler, 438 F.3d 804, 809 (7th Cir. 2006). “To exhaust remedies, a prisoner must file complaints and appeals in the place, and at the time, the prison’s administrative rules require.” Pozo v. McCaughtry, 286 F. 3d 1022, 1025 (7th Cir. 2002).

Furthermore, exhaustion of available administrative remedies must occur before the suit is filed. Ford v. Johnson, 362 F.3d 395, 398 (7th Cir. 2004). III. Grievance Procedures As an inmate in the custody of IDOC at the time of filing, Plaintiff was required to follow the grievance procedure laid out in the Illinois Administrative Code (“grievance procedures”). 20 ILL. ADMIN. CODE § 504.800, et seq. The grievance procedures direct an inmate is to file a grievance first with the Counselor within 60 days of the discovery of an incident. See 20 ILL. ADMIN. CODE § 504.810(a). The grievance form must: [C]ontain factual details regarding each aspect of the offender’s complaint, including what happened, when, where, and the name of each person who is the subject of or who is otherwise involved in the complaint. This provision does not preclude an offender from filing a grievance when the names of individuals are not known, but the offender must include as much descriptive information about the individual as possible.

20 ILL. ADMIN. CODE § 504.810(c). Grievances that are unable to be resolved through routine channels are then sent to a Grievance Officer. See 20 ILL. ADMIN. CODE § 504.820(a). The Grievance Officer will review the grievance and provide a written response to the inmate. See 20 ILL. ADMIN. CODE § 504.830(a). The Grievance Officer must submit his findings to the Chief Administrative Officer (CAO) within two months after receiving the grievance. 20 ILL. ADMIN. CODe § 504.830(e). The CAO then reviews the findings and recommendation of the Grievance Officer and issues a written decision to the inmate. Id. If the inmate is not satisfied with the response, he can file an appeal with the Administrative Review Board (ARB). See 20 ILL. ADMIN. CODE § 504.850(a). The ARB must receive the appeal within 30 days after the date of the decision by the CAO, and copies of “the Grievance Officer’s report and the Chief Administrative Officer’s decision should be attached.” Id. Only after a grievance is reviewed by the ARB is it deemed exhausted. See Pozo, 286 F.3d at 1023–24.

ANALYSIS The only grievance at issue in this case is Grievance #232557, dated June 28, 2023. (Doc. 67, p. 3). In Grievance #232557, Plaintiff grieves that on June 9, 2023, a correctional officer claimed that Plaintiff had a fight with his cellmate and was smoking. Plaintiff claims that these allegations were “made up [and] a lie.” He writes that he was issued a disciplinary ticket and placed in segregation. While in segregation, he began cutting himself and “banging his head…” He showed Mental Health Professional (MHP) Ms. S cuts on his arms, and he was eventually taken to the health care unit. He states that he was not seen by a nurse or other medical staff for his injuries. Plaintiff alleges in the grievance that he was told that he wants to die “so die.” He states that Defendant Fulk came into the room, but he did not talk to Defendant Fulk because she “was

talking to [him] unkind and rude.” Then he was taken to a crisis cell. (Id. at p. 4). In his request for relief, Plaintiff asks for the disciplinary ticket to be removed from his record, for his A-grade status to be reinstated, to be removed from “confinement,” for proper mental health treatment, and to receive compensation for the mental stress he has endured. (Id. at p. 3). On August 4, 2023, the grievance officer recommended for Plaintiff’s grievance to be denied because he was never issued a disciplinary ticket. (Doc. 67, p. 2).

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