Woods v. Gladieux

District Court, N.D. Indiana·Decided March 27, 2023·No. 1:22-cv-00383·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

LINZEY WOODS,

Plaintiff,

v. CAUSE NO. 1:22-CV-383-HAB-SLC

DAVID J. GLADIEUX,

Defendant.

OPINION AND ORDER Linzey Woods, a prisoner without a lawyer, filed a complaint against Allen County Sheriff David Gladieux seeking damages for being held in the unconstitutional conditions of confinement at the Allen County Jail identified in Morris v. Sheriff of Allen County, No. 1:20-CV-34-DRL, 2022 WL 971098 (N.D. Ind. Mar. 31, 2022). ECF 1. The court determined the complaint did not state a claim because Woods did not allege how he was personally injured by the conditions. ECF 4. Woods has now filed an amended complaint with more detail about the conditions of confinement he experienced in the seven-month period from November 24, 2021, through June 16, 2022, that he was detained at the jail. ECF 5. Under 28 U.S.C. § 1915A, the court must review the merits of a prisoner complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. “A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted).

Woods alleges he was a pre-trial detainee while at the Allen County Jail, and therefore his rights arise under the Fourteenth Amendment. Miranda v. Cnty. of Lake, 900 F.3d 335, 352 (7th Cir. 2018) (citing Kingsley v. Hendrickson, 576 U.S. 389 (2015)). “[T]he Fourteenth Amendment’s Due Process Clause prohibits holding pretrial detainees in conditions that ‘amount to punishment.’” Mulvania v. Sheriff of Rock Island Cnty., 850 F.3d 849, 856 (7th Cir. 2017) (citation omitted). To state a claim that a jail policy violates

the Fourteenth Amendment, a plaintiff must allege that a resulting pretrial condition “is ‘imposed for the purpose of punishment,’ or . . . the condition ‘is not reasonably related to a legitimate goal—if it is arbitrary or purposeless . . ..’” Id. at 856 (quoting Bell v. Wolfish, 441 U.S. 520, 538-39 (1979). Courts consider whether “the challenged governmental action is not rationally related to a legitimate governmental objective or

[whether] it is excessive in relation to that purpose.” Id. (quoting Kingsley, 576 U.S. at 398). Overcrowding, on its own, does not state a constitutional claim, and instead the court must look to the effects the overcrowding has on the conditions of confinement. See Bell v. Wolfish, 441 U.S. 520, 541 (1979) (“While confining a given number of people

in a given amount of space in such a manner as to cause them to endure genuine privations and hardship over an extended period of time might raise serious questions under the Due Process Clause as to whether those conditions amounted to punishment, nothing even approaching such hardship is shown by this record.”); see also Hubbard v. Taylor, 538 F.3d 229 (3d Cir. 2008) (after determining that the triple-celling of pretrial detainees was rationally related to managing an overcrowded facility, the court turned

to “whether these conditions cause inmates to endure such genuine privations and hardship over an extended period of time, that the adverse conditions because excessive in relation to the purposes assigned to them” (quotation marks omitted)). For example, overcrowding could lead to deprivations of essential food, medical care, or sanitation, cause an increase in violence, or result in other intolerable prison conditions. Rhodes v. Chapman, 452 U.S. 337, 348 (1981).

Woods’ amended complaint plausibly alleges that as a result of the overcrowding, he was subjected to unconstitutional conditions of confinement that injured him. For example, Woods alleges that in the seven months he was detained at the jail, he was not given any recreation time or other opportunities to exercise. As a result, he experienced muscle loss and physical pain, and the tension from

overcrowding and lack of privacy caused him severe anxiety. Woods plausibly alleges that spending seven months in overcrowded conditions, coupled with the lack of recreation, could amount to punishment. Cf. James v. Pfister, 708 F. App’x 876, 879 (7th Cir. 2017) (“Our decisions are clear that preventing inmates from exercising for prolonged periods may violate the Eighth Amendment.”); Gray v. Hardy, 826 F.3d 1000,

1005 (7th Cir. 2016) (“An adverse condition of confinement, if endured over a significant time, can become an Eighth Amendment violation even if it would not be impermissible if it were only a short-term problem.”). Woods further alleges that he had to sleep with inadequate bedding on the floor in the dayroom, where the lights were on 24 hours a day. He alleges that this prevented

him from getting enough rest, which caused him physical and mental strain. Sleeping on the floor is not, by itself, a constitutional violation. See, e.g., Rodmaker v. Krienhop, No. 4:14-cv-070-TWP-TAB, 2014 U.S. Dist. LEXIS 100067 at *6 (S.D. Ind. July 23, 2014) (collecting cases) (pretrial detainees have no constitutional right to have an elevated bed and may be required to sleep with their mattress on the floor); Robeson v. Squadrito, 57 F. Supp. 2d 645, 647 (N.D. Ind. 1999) (same). But under the circumstances here, Woods

plausibly alleges that he was prevented from obtaining adequate sleep for a long period of time with the combination of 24-hour lighting and overcrowded inmates sleeping on the floor with inadequate bedding. Woods also alleges the overcrowding led to limited access to the toilet and shower. He contends the floors, toilets, and vents were filthy from so many people

living together. He says the vents were black and moldy, and he was exposed to fecal matter from the unclean toilets and floors. Here, he plausibly alleges that he was denied “reasonably adequate” sanitation. See Hardeman v. Curran, 933 F.3d 816, 820 (7th Cir. 2019) (detainees are entitled to “reasonably adequate” sanitation and their allegation that they were forced to live “surrounded by their own and others’ excrement” for

several days stated Fourteenth Amendment claim). Finally, Woods complains about limitations on his ability to practice his religion at the jail. He says there was no church or chapel offered during his stay at the jail. Inmates retain their right under the First Amendment to practice their religion. Kaufman v. McCaughtry, 419 F.3d 678, 681 (7th Cir. 2005). “The Free Exercise Clause prohibits the state from imposing a substantial burden on a central religious belief or

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Related

Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Cutter v. Wilkinson
544 U.S. 709 (Supreme Court, 2005)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
James J. Kaufman v. Gary R. McCaughtry
419 F.3d 678 (Seventh Circuit, 2005)
Hubbard v. Taylor
538 F.3d 229 (Third Circuit, 2008)
Robeson v. Squadrito
57 F. Supp. 2d 642 (N.D. Indiana, 1999)
James J. Kaufman v. Jeffrey Pugh
733 F.3d 692 (Seventh Circuit, 2013)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Marcos Gray v. Marcus Hardy
826 F.3d 1000 (Seventh Circuit, 2016)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Tapanga Hardeman v. David Wathen
933 F.3d 816 (Seventh Circuit, 2019)
Mulvania v. Sheriff of Rock Island County
850 F.3d 849 (Seventh Circuit, 2017)
James v. Pfister
708 F. App'x 876 (Seventh Circuit, 2017)