Tatum v. Criage

CourtDistrict Court, S.D. Illinois
DecidedMay 17, 2024
Docket3:24-cv-01183
StatusUnknown

This text of Tatum v. Criage (Tatum v. Criage) 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
Tatum v. Criage, (S.D. Ill. 2024).

Opinion

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

BOBBY TATUM,

Plaintiff,

v. Case No. 24-cv-1183-NJR

C/O CRIAGE, C/O REED, C/O JOHN DOE #1, LT. AUSTIN, KELLY BEAL, LT. CHRISTAN, WARDEN GALLOWAY, SGT. STROUD, and SGT. PILLOT,

Defendants.

MEMORANDUM AND ORDER ROSENSTENGEL, Chief Judge: Plaintiff Bobby Tatum, an inmate of the Illinois Department of Corrections who is currently incarcerated at Shawnee Correctional Center, brings this action for deprivations of his constitutional rights pursuant to 42 U.S.C. § 1983. On April 29, 2024, Tatum filed a Complaint alleging that his First and Eighth Amendment rights were violated by Defendants. On May 15, 2024, Tatum filed an Amended Complaint alleging violations of his First, Eighth, and Fourteenth Amendment rights.1 This case is now before the Court for preliminary review of the Amended Complaint pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to

1 The Amended Complaint is now the operative pleading, and the Court will conduct a preliminary review of only the claims raised in the amended pleading. Tatum’s original Complaint failed to provide enough factual allegations to put the defendants on notice of the claims against them. He simply referred to allegations he raised in another of his pending cases and stated that his rights were violated in the manner set forth in the Court’s Order in that case. screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). 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). The Amended Complaint In the Amended Complaint, Tatum makes the following allegations: On August 6, 2023, Tatum walked past Warden Galloway on his way to lunch (Doc. 11, p. 8). He overheard Galloway say that he was going to make Tatum pay for filing lawsuits against

staff (Id.). Upon returning to his cell from lunch, officers came to Tatum’s cell and told him that he was being moved to another cell in Cellhouse 2, on the warden’s orders (Id.). Tatum believes that the transfer was in retaliation for filing grievances and lawsuits against Galloway’s staff at Shawnee (Id. at p. 7). Upon arriving at his new cellhouse, Sergeant Pillot and Correctional Officer

(“C/O”) Criage informed Tatum that Galloway directed them to “kick your butt” for filing grievances and lawsuits (Id.). The officers then grabbed his cuffed wrists and tried to break them (Id.). They also ran his forehead into a glass window, knocking Tatum unconscious (Id.). Tatum alleges an unknown John Doe officer failed to intervene. After the assault, Pillot and Criage wrote a false disciplinary ticket in violation of Tatum’s due

process rights, and he was deprived of a fair hearing (Id.). Directly after the assault, the officers called Lieutenant Austin and Lieutenant Christan (Id. at pp. 8-9). Tatum alleges that he was just standing in the cellhouse, cuffed, and bleeding (Id.). Tatum’s pants had also fallen down, or were pulled down during the earlier assault, and his genitals and buttocks were visible to all of the inmates in the cellhouse (Id. at p. 9). He asked Austin and Christan to pull up his pants, but they refused

and walked him down the gallery exposed to all of the inmates in the cellhouse (Id.). Christan and Austin also informed Tatum that they were on orders from Galloway to kill Tatum due to his numerous grievances and lawsuits (Id.). They then pulled his arms backwards in an attempt to break his shoulders and dropped him face first on the ground, causing his nose to bleed (Id.). Tatum again blacked out from his injuries (Id.). While Tatum was unconscious, he alleges that Lieutenant Beal, Austin, and

Christan sexually assaulted him with a stick, causing tears and bleeding (Id.). Although he begged the officers to stop, they refused and yelled at the inmates on the gallery, telling them that this is what happens to inmates who file grievances and lawsuits (Id.). Tatum alleges C/O Reed failed to intervene in the assault and then denied Tatum a fair disciplinary hearing when she heard a ticket on the incident (Id.). He alleges that both

C/O Reed and Lieutenant Bradford found him guilty of refusing to cuff-up (Id. at p. 10). After the sexual assault, Sergeant Stroud helped the other officers place Tatum in a segregation holding cell. Stroud slammed Tatum’s face into the holding cell window causing additional pain and injuries (Id. at p. 10). Stroud stated that he had been ordered by Beal, Christan, Austin, and Warden Galloway to attack Tatum because he filed

grievances and lawsuits (Id.). A nurse later approached Tatum’s cell, but Lieutenant Beal told the nurse to leave the cellhouse and to not treat Tatum (Id. at p. 10). Tatum also alleges that Beal chose a cell that was covered in blood and feces (Id.). The smell caused Tatum’s eyes to burn (Id.). The cell was also covered in mold, and the windows were broken (Id.).

Tatum alleges that he wrote grievances about the attacks and retaliation efforts of the officers, but Administrative Review Board chairperson Marget Madole denied his grievance (Id. at p. 6). He alleges her actions aided the defendants in their retaliation campaign and failed to protect Tatum from future assaults (Id.). She also failed to provide him with medical care (Id.). He alleges that Rob Jeffreys also had the power to help Tatum after the assault but denied his grievances, thereby denying him medical treatment for

his injuries (Id.). He alleges that denial also left Tatum vulnerable to future attack. Tatum alleges Jeffreys was aware of the conditions at Shawnee but continued to place inmates like Tatum at the prison. Preliminary Dismissals As an initial matter, Tatum fails to properly identify Lieutenant Bradford, Marget

Madole, and Rob Jeffreys in the case caption as defendants. See Myles v. United States, 416 F.3d 551, 551–52 (7th Cir. 2005) (to be properly considered a party a defendant must be “specif[ied] in the caption”). Even if Tatum had properly identified these defendants in the case caption, he fails to state a claim against them. Tatum alleges that Madole and Jeffreys denied his grievances regarding the assault and his access to medical care after

the assault. But these officials cannot be liable for simply responding to or denying his grievances. Owens v. Hinsley, 635 F.3d 950, 953 (7th Cir. 2011) (stating that “the alleged mishandling of [a prisoner’s] grievance by persons who otherwise did not cause or participate in the underlying conduct states no claim.”). There are no allegations to suggest that they were aware of the assault at the time or could have acted to protect Tatum from the assault. Thus, any claim against the grievance officials, including for

failure to protect or failure to obtain medical care for Tatum, are DISMISSED without prejudice. Tatum also fails to state a claim against Lieutenant Bradford. He alleges that Bradford and Reed violated his due process rights when they acted as impartial decision makers and found him guilty on the charges stemming from the assault.

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