Weldon v. Cahokia Police Department

CourtDistrict Court, S.D. Illinois
DecidedOctober 20, 2021
Docket3:21-cv-00684
StatusUnknown

This text of Weldon v. Cahokia Police Department (Weldon v. Cahokia Police Department) 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
Weldon v. Cahokia Police Department, (S.D. Ill. 2021).

Opinion

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

WILLIE WELDON, #Y45784, ) ) Plaintiff, ) ) vs. ) Case No. 21-cv-00684-JPG ) CAHOKIA POLICE DEPARTMENT ) and RICHARD WATSON, ) ) Defendants. )

MEMORANDUM AND ORDER GILBERT, District Judge: Plaintiff Willie Weldon, an inmate who is currently incarcerated in Pinckneyville Correctional Center, brings this action for constitutional deprivations pursuant to 42 U.S.C. § 1983. In the Complaint, Plaintiff alleges that he was subjected to the unlawful use of force during his arrest by Cahokia Police Department that resulted in a concussion, broken arm, and bruising in March 2019. (Doc. 1, p. 6). He was then denied medical treatment for his injuries at St. Clair County Jail. (Id.). Plaintiff brings a claim of excessive force against the arresting agency, i.e., Cahokia Police Department, and a claim for the denial of medical care against the holding agency, i.e., St. Clair County Jail / Sheriff Richard Watson. (Id.). He seeks money damages. (Id. at 7). The Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A, which requires the Court to 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 or malicious, fails to state a claim upon which relief may be granted, or asks for money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The factual allegations of the pro se complaint are liberally construed at this stage. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). Before the Court screens the Complaint, however, it must first determinate whether any claims are improperly joined in this action and subject to severance. George v. Smith, 507 F.3d 605, 607 (7th Cir. 2007). Discussion

Based on the allegations in the Complaint, the Court finds it convenient to divide the pro se action into the following enumerated counts: Count 1: Fourth Amendment claim against Cahokia Police Department for using excessive force against Plaintiff during his arrest in March 2019.

Count 2: Fourth, Fourteenth, or Eighth Amendment claim against Sheriff Watson for denying Plaintiff medical care for injuries he sustained during his arrest in March 2019, after he was detained at St. Clair County Jail in March 2019.

The parties and the Court will use these designations in all future pleadings and orders, unless otherwise directed by a judicial officer of this Court. Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard.1 Severance Plaintiff’s two claims involve distinct groups of defendants, separate transactions or occurrences, few common questions of fact, and different legal theories. As such, the two claims cannot proceed together in the same suit. See FED. R. CIV. P. 18, 20(a)(2). District courts must apply Rule 20 of the Federal Rules of Civil Procedure to prevent improperly joined parties from proceeding together in the same case. George, 507 F.3d at 607. Rule 21 of the Federal Rules of Civil Procedure grants district courts broad discretion when deciding whether to sever claims or to dismiss improperly joined defendants. Owens v. Hinsley, 635 F.3d 950, 952 (7th Cir. 2011).

1 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face”). Plaintiff’s excessive force claim in Count 1 against Cahokia Police Department cannot proceed together with his claim for denial of medical care in Count 2 against Sheriff Watson. Accordingly, Count 2 shall be severed into a separate suit, assigned a new case number, and assessed an additional filing fee of $402.00. If Plaintiff chooses to proceed with the severed case, the Court will screen Count 2 under 28 U.S.C. § 1915A.

Count 1 Count 1 is now subject to preliminary review under 28 U.S.C. § 1915A. Claims of excessive force during a stop, arrest, or other seizure of a free citizen are analyzed under the Fourth Amendment’s reasonableness standard. Dockery v. Blackburn, 911 F.3d 458, 464 (7th Cir. 2018) (citing Graham v. Connor, 490 U.S. 386, 395-97 (1989)). What is considered reasonable or excessive in the way of force turns on the totality of the circumstances viewed from the standpoint of a “reasonable officer on the scene.” Id. See also Richman v. Sheahan, 512 F.3d 876, 885 (7th Cir. 2008). As with other claims brought pursuant to Section 1983, this claim must be brought against a “person” subject to suit under the statute.

Cahokia Police Department is not a “person” who is subject to suit under Section 1983. Plaintiff’s designation of this defendant may represent an attempt to hold a municipality liable for his injuries. See Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 690, 694 (1978). Municipal liability under Section 1983 arises from the execution of a government policy, custom, or widespread practice that causes a constitutional injury. Id. However, Plaintiff points to no such policy, custom, or widespread practice. Count 1 thus fails to state any claim for relief against this defendant and shall be dismissed. Pending Motion Plaintiff’s Motion for Recruitment of Counsel (Doc. 3) is DENIED without prejudice. When the Court is presented with a request for counsel by an indigent litigant, it must first consider whether the plaintiff has made reasonable attempts to secure counsel on his own, and, if so, whether the difficulty of the case, both factually and legally, exceeds his capacity as a layperson

to present it. Navejar v. Iyiola, 718 F.3d 692, 696 (7th Cir. 2013) (citing Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007)). Plaintiff indicates that he lacks the resources necessary to retain counsel, but this misses the point. He must at least try to contact three attorneys to request pro bono representation before asking the Court to help him find counsel.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
Rudolph Lucien v. Diane Jockisch
133 F.3d 464 (Seventh Circuit, 1998)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Richman v. Sheahan
512 F.3d 876 (Seventh Circuit, 2008)
Eduardo Navejar v. Akinola Iyiola
718 F.3d 692 (Seventh Circuit, 2013)
Patrick Dockery v. Sherrie Blackburn
911 F.3d 458 (Seventh Circuit, 2018)

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Weldon v. Cahokia Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weldon-v-cahokia-police-department-ilsd-2021.