Wilson v. Hughes

CourtDistrict Court, S.D. Illinois
DecidedJanuary 23, 2025
Docket3:24-cv-02196
StatusUnknown

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

Opinion

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

JABER WILSON, #R34144, ) ) Plaintiff, ) ) vs. ) Case No. 24-cv-02196-SMY ) LATOYA HUGHES, ) ANTHONY D. WILLS, ) LT. LENEAR, ) M. ROSE, ) JOSHUA SCHOENBECK, ) and ANTHONY B. JONES, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Jaber Wilson, an inmate in the custody of the Illinois Department of Corrections (IDOC), filed this lawsuit pursuant to 42 U.S.C. § 1983 to challenge disciplinary tickets he received at Menard Correctional Center (Menard) for his involvement in a staff assault at Lawrence Correctional Center (Lawrence). The Complaint (Doc. 1) is now subject to preliminary review under 28 U.S.C. § 1915A, which requires this Court to dismiss any portion that is legally frivolous or malicious, fails to state a claim for relief, or seeks money damages from an immune defendant. The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 1, pp. 1-51): Plaintiff received two unsigned disciplinary tickets on January 3, 2023, issued by Lieutenant Lenear on December 31, 2022, and Officer Rose on January 2, 2023. The tickets stemmed from a staff assault that occurred at Lawrence Correctional Center on December 28, 2022. Another inmate instigated the attack on staff and unlocked Plaintiff’s cell door using keys he obtained from an officer. Plaintiff noticed his door open unexpectedly and exited the cell to find out why there was a commotion nearby. Officers sprayed him with pepper spray, and he defended himself. The same day, Plaintiff was transferred from administrative detention at Lawrence to restrictive housing at Menard. He was then issued two disciplinary tickets citing violations of the

following IDOC rules: (1) Rule 100 – violent assault of any person – staff; (2) Rule 102a – assault with injury; (3) Rule 102b – assault; (4) Rule 104 – dangerous contraband; (5) Rule 105 – dangerous disturbances; (6) Rule 106 (Attempt) – escape; (7) Rule 202 – damage or misuse of property; (8) Rule 206 – intimidation or threats; and (9) Rule 215 – disobeying a direct order essential to safety. Id. at 40. Plaintiff pleaded not guilty at a disciplinary hearing before Menard’s Adjustment Committee on January 11, 2023. He attempted to present a written statement with a list of facts, evidence, and witnesses that supported his case. He argued that the rule violations were fabricated and that video footage of the incident confirmed this. He also requested the presence of a mental health staff member, consideration of a related investigatory report, and review of the video of the

incident at the hearing. However, Plaintiff was not allowed to call witnesses or present exculpatory evidence. Plaintiff was found guilty of all rule violations and punished with 6 months in segregation, 6 months of contact visit restrictions, and 3 months of C-grade. Id. at 40-41. He is now classified as a weapons violator with an extremely high escape risk (Level E) and is subjected to weekly cell shakedowns, bimonthly cell relocation, and biennial prison transfers. Id. at 12. Plaintiff suffered additional punishment because he was denied access to showers, yard, audio-visual equipment, personal property, tools, clothing, food, and a job, resulting in additional emotional distress. Id. CAO Wills concurred with the findings of the Adjustment Committee on February 10, 2023, and IDOC Director Latoya Hughes denied Plaintiff’s related grievance(s). Id. Discussion Based on the allegations, the Court designates the following claims in the Complaint: Count 1: Fourteenth Amendment claim against Defendants for depriving Plaintiff of a protected liberty interest without due process of law by punishing him with 6 months in segregation, 6 months of contact visit restrictions, and 3 months of C-grade for two false disciplinary tickets issued by Lieutenant Lenear on or around December 31, 2022 and Officer Rose on or around January 2, 2023.

Count 2: Eighth Amendment claim against Defendants for subjecting Plaintiff to unconstitutional conditions of confinement by denying him access to the showers, yard, audio-visual equipment, personal property, tools, clothing, food, and a job for unspecified periods of time at Menard.

Any other claim mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). Count 1 The Fourteenth Amendment guards against deprivations of “life, liberty, or property” without due process of law. Zinermon v. Burch, 494 U.S. 113, 125 (1990). To state a due process claim in the prison disciplinary context, Plaintiff must plead facts demonstrating (1) the existence of a constitutionally protected liberty interest that triggers the right to due process of law; and (2) deficient procedures in the disciplinary proceedings. Lisle v. Welborn, 933 F.3d 705, 720 (2019). When determining whether a protected liberty interest was at stake, the court looks to the duration of confinement in segregation and the conditions endured there. Ealy v. v. Watson, 109 F.4 958, 964 (7th Cir. 2024). For shorter periods of confinement in segregation, no inquiry into the specific conditions is typically necessary. See Thomas v. Ramos, 130 F.3d 754, 761 (7th Cir. 1997) (70 days); Marion v. Columbia Corr. Inst., 559 F.3d 693, 697-98 (7th Cir. 2009) (240 days). For longer periods, the court considers whether Plaintiff faced an “atypical and significant hardship” in segregation. Sandin v. Conner, 515 U.S. 472, 484 (1995). Here, Plaintiff was punished with 6 months in segregation, which is generally not considered long enough to trigger due process protections when standing alone. Marion, 559 F.3d

at 698. His additional restriction on contact visits and demotion to C-grade add nothing to this claim. See Wood v. Zatecky, 594 F. App’x 311 (7th Cir. 2015); Lekas v. Briley, 405 F.3d 602 (7th Cir. 2005) (no liberty interest implicated by denial of contact visits and demotion to C-grade). However, Plaintiff indicates that he suffered additional punishment, in the form of denied access to showers, yard, audio-visual equipment, personal property, tools, clothing, food, and a job, and he continues to face punishment in the form of weekly cell searches, bimonthly cell relocations, and biennial prison transfers; all of which has exacerbated his serious mental illness. Construing these allegations liberally in favor of the pro se plaintiff, the Court finds that the Complaint describes a protected liberty interest. Kervin v. Barnes, 787 F.3d 833, 836 (7th Cir. 2015) (Fewer than six months in disciplinary segregation can establish a liberty interest “depending on the

conditions of confinement.”). The Court must also consider whether the Complaint describes a violation of due process protections.

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Related

Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Christopher Lekas v. Kenneth Briley
405 F.3d 602 (Seventh Circuit, 2005)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Marion v. Columbia Correctional Institution
559 F.3d 693 (Seventh Circuit, 2009)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)
Benjamin Woody v. Dushan Zatecky
594 F. App'x 311 (Seventh Circuit, 2015)
Shane Kervin v. La Clair Barnes
787 F.3d 833 (Seventh Circuit, 2015)
Marcos Gray v. Marcus Hardy
826 F.3d 1000 (Seventh Circuit, 2016)
Steven Lisle, Jr. v. William Welborn
933 F.3d 705 (Seventh Circuit, 2019)
Haywood v. Hathaway
842 F.3d 1026 (Seventh Circuit, 2016)
Benjamin Adams v. Christina Reagle
91 F.4th 880 (Seventh Circuit, 2024)

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