Welborn v. Truitt

CourtDistrict Court, N.D. Illinois
DecidedMarch 25, 2025
Docket1:24-cv-03165
StatusUnknown

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

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Welborn v. Truitt, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

FRANCINE WELBORN, as Representative of the Estate of LOVELLE ANTONIO JORDAN,

Plaintiff, No. 24 CV 3165

v. Judge Manish S. Shah

CHARLES TRUITT, Warden of The Stateville Correctional Center, and UNKNOWN JOE DOE CORRECTIONAL OFFICERS,

Defendants.

MEMORANDUM OPINION AND ORDER

Lovelle Jordan was a prisoner at Stateville Correctional Center serving a 31- year sentence. He was housed in a special needs unit because he was paralyzed from the chest down and had limited mobility in his upper extremities. In April 2022, Jordan died by suicide while in custody. Plaintiff Francine Welborn, Jordan’s mother and representative of his estate, brings constitutional, negligence, wrongful death, and survival claims against Stateville’s warden, defendant Charles Truitt, and unknown correctional officers. Truitt moves to dismiss the claims against him. I. Legal Standards When reviewing a Federal Rule of Civil Procedure 12(b)(6) motion to dismiss, a court accepts all well-pled allegations as true and draws all reasonable inferences in favor of the plaintiff. Gociman v. Loyola Univ. of Chi., 41 F.4th 873, 881 (7th Cir. 2022). “To survive a motion to dismiss, a plaintiff must plead ‘only enough facts to state a claim to relief that is plausible on its face.’” Id. (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). II. Facts

Lovelle Jordan was a prisoner in the custody of the Illinois Department of Corrections at the Stateville Correctional Center serving a 31-year sentence. [9] ¶ 7.1 Jordan was housed in a unit for his special needs as a paraplegic. [9] ¶ 8. He was paralyzed from the chest down, had limited mobility, and did not have full range of motion in his upper extremities. Id. On April 19, 2022, Jordan hung himself in his cell. [9] ¶ 9. Other detainees called for help, shouting “urgent warnings,” but correctional officers did not timely respond. [9] ¶¶ 15, 23. Jordan was removed from

his cell and transported to a medical center where he was pronounced dead. [9] ¶ 10. Defendant Charles Truitt was the Warden at Stateville at the time of Jordan’s death. [9] ¶ 5. Plaintiff Francine Welborn, Jordan’s mother and representative of his estate, brings 42 U.S.C. § 1983 claims for violations of Jordan’s Fourth, Fifth, Eighth, and Fourteenth Amendment rights. [9] ¶¶ 4, 12–19. She also brings negligence, wrongful death, and survival claims under Illinois law. [9] ¶¶ 20–34. Defendant Charles Truitt

moves to dismiss. [19].

1 Bracketed numbers refer to entries on the district court docket. Referenced page numbers are taken from the CM/ECF header placed at the top of filings. When a document has numbered paragraphs, I cite to the paragraph, for example [9] ¶ 1. The facts are taken from plaintiff’s amended complaint, [9]. III. Analysis A. 42 U.S.C. § 1983 Claims Welborn invokes the Fourth, Fifth, Eighth, and Fourteenth Amendments as grounds for her § 1983 claims. [9] ¶¶ 14–19. The theory underlying all the alleged

constitutional violations is the same: defendants failed to properly screen or recognize Jordan’s risk for suicide, to properly monitor him, and to respond to his needs or assist him when other inmates called for help. [9] ¶¶ 13, 15–17. As a convicted prisoner, Jordan’s rights regarding conditions of confinement arose under the Eighth Amendment. See Farmer v. Brennan, 511 U.S. 825, 832 (1994) “[I]t is . . . settled that the treatment a prisoner receives in prison and the conditions under which he is confined are subject to scrutiny under the Eighth Amendment.” Id.

The Fourth, Fifth, and Fourteenth Amendments do not apply here. The Fourth Amendment “governs [conditions of confinement during] the period of confinement between arrest without a warrant and the probable cause determination.” Currie v. Chhabra, 728 F.3d 626, 629 (7th Cir. 2013); see Pulera v. Sarzant, 966 F.3d 540, 549 (7th Cir. 2020). The Fourteenth Amendment’s covers conditions of confinement for pretrial detainees. Miranda v. County of Lake, 900 F.3d 335, 350 (7th Cir. 2018). And

the Fifth Amendment only limits the acts of the federal government, its agencies, and officers, not state actors like defendants. See Conley v. United States, 5 F.4th 781, 788 n.1 (7th Cir. 2021) (citing Bolling v. Sharpe, 347 U.S. 497, 498–500 (1954)). Welborn’s § 1983 claims based on the Fourth, Fifth, and Fourteenth Amendments against Truitt, and all other (unidentified and unserved correctional officer) defendants, are dismissed with prejudice.2 To state a claim under the Eighth Amendment for an inmate’s suicide, a

plaintiff must plausibly allege that a prison official was “cognizant of the significant likelihood that an inmate may imminently seek to take his own life and [] fail[ed] to take reasonable steps to prevent the inmate from performing this act.” Sanville v. McCaughtry, 266 F.3d 724, 737 (7th Cir. 2001); Est. of Miller, ex rel. Bertram v. Tobiasz, 680 F.3d 984, 989 (7th Cir. 2012). The allegations here do not suggest that Truitt was subjectively aware that

Jordan was at risk of suicide, and that Truitt knowingly or recklessly disregarded this risk. Welborn alleges that defendants failed to “adequately screen Lovelle Jordan for depression and/or suicidal ideation, [] fail[ed] to properly observe and monitor him, and fail[ed] to respond to his needs or assist him.” [9] ¶ 13. But she does not allege that Truitt was involved in Jordan’s intake or mental health evaluation, that he ever received any information that Jordan was at risk of suicide, that he was aware of any prior history of depression or suicide attempts, or that he had any direct contact or

communication with Jordan. No facts “suggest that [Truitt] had been exposed to information concerning the risk and thus must have known about it.” See Sanville, 266 F.3d at 737.

2 While first dismissals are typically granted without prejudice, no amendments would establish that the Fourth, Fifth, or Fourteenth Amendments’ protections apply here. “[D]ismissals without prior notice or opportunity to be heard are hazardous,” but the defect here is “clearly incurable” as to all defendants. See Luevano v. Wal-Mart Stores, Inc., 722 F.3d 1014, 1022–23 (7th Cir. 2013). Welborn argues that her failure to plead detailed facts about Truitt’s personal involvement is not grounds for dismissal at this stage. [22] at 5–7. She says this is particularly true because Jordan is deceased, and it would be unreasonable to expect

more specific allegations until the parties have conducted discovery. [22] at 6–7.

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Related

Bolling v. Sharpe
347 U.S. 497 (Supreme Court, 1954)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Sanville v. Mccaughtry
266 F.3d 724 (Seventh Circuit, 2001)
Estate of Miller, Ex Rel. Bertram v. Tobiasz
680 F.3d 984 (Seventh Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Turpin v. Koropchak
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Fritz v. Johnston
807 N.E.2d 461 (Illinois Supreme Court, 2004)
Loman v. Freeman
890 N.E.2d 446 (Illinois Supreme Court, 2008)
Healy v. Vaupel
549 N.E.2d 1240 (Illinois Supreme Court, 1990)
Jaclyn Currie v. Jogendra Chhabra
728 F.3d 626 (Seventh Circuit, 2013)
Tara Luevano v. Walmart Stores, Incorporated
722 F.3d 1014 (Seventh Circuit, 2013)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Zachary Pulera v. Victoria Sarzant
966 F.3d 540 (Seventh Circuit, 2020)
Tracy Conley v. United States
5 F. 4th 781 (Seventh Circuit, 2021)
Andreea Gociman v. Loyola University of Chicago
41 F.4th 873 (Seventh Circuit, 2022)
T. S. v. County of Cook
67 F.4th 884 (Seventh Circuit, 2023)

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