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Williams v. Sangamon County Jail

United States District Court, C.D. Illinois, Springfield Division

April 7, 2014

JAMES F. WILLIAMS, JR., Plaintiff,
v.
SANGAMON COUNTY JAIL, Defendant.

MERIT REVIEW OPINION

SUE E. MYERSCOUGH, District Judge.

This cause is before the Court for a merit review, pursuant to 28 U.S.C. § 1915A, of Plaintiff James F. Williams, Jr.'s claims.

I.

MERIT REVIEW UNDER 28 U.S.C. § 1915(A)

Under 28 U.S.C. § 1915(e)(2) and § 1915A, the Court is required to carefully screen a complaint filed by a plaintiff who seeks to proceed in forma pauperis. The Court must dismiss a complaint, or a portion thereof, if the plaintiff has raised claims that are legally "frivolous or malicious, " that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. Id.

The test for determining if an action is frivolous or without merit is whether the plaintiff can make a rational argument on the law or facts in support of the claim. Neitzke v. Williams, 490 U.S. 319, 325 (1989). A complaint fails to state a claim for relief if the complaint does not allege "enough facts to state a claim to relief that is plausible on its face." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007); Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009).

In reviewing the complaint, the Court accepts the factual allegations as true and liberally construes them in plaintiff's favor. Turley v. Rednour, 729 F.3d 645, 651 (7th Cir. 2013). Conclusory statements and labels are insufficient. Fed.R.Civ.P. 8; Schatz v. Republican State Leadership Comm., 669 F.3d 50, 55 (1st Cir. 2012) (holding that, in order to determine if a complaint states a plausible claim, the court must take non-conclusory, non-speculative facts as true, draw all reasonable inferences in the pleader's favor, and isolate and ignore statements that simply rehash claim elements or offer only legal labels and conclusions). Instead, sufficient facts must be provided to "state a claim for relief that is plausible on its face." Alexander v. United States, 721 F.3d 418, 422 (7th Cir. 2013)(internal quotation omitted).

II.

ANALYSIS

Williams is a pre-trial detainee located at the Sangamon County Jail (also known as the Sangamon County Detention Center) and is currently awaiting trial. Williams alleges that he has been injured twice while cleaning the air vent in his cell. The first time, Williams scraped his finger on a piece of metal that was protruding from the vent. Williams acknowledges that this first injury was not serious.

The second time, a piece of metal fell from the vent into Williams' eye. Williams required and received medical attention for his eye injury. Jail officials came to Williams' cell two days later and cleaned the air duct and vent in Williams' cell.

Williams claims that the Jail officials have subjected him to cruel and unusual punishment by forcing him to live in unsanitary conditions based upon the fact that the air vents were rusty and dirty. This condition led to the metal falling into his eye and forced him to breathe dirty air.

The Fourteenth Amendment's due process clause provides protections to Williams as a pre-trial detainee. Brown v. Budz, 398 F.3d 904, 910 (7th Cir. 2005). The United States Court of Appeals for the Seventh Circuit has stated that the Fourteenth Amendment's protections are "at least as great as the protections available to a convicted prisoner under the Eight Amendment.'" Tesch v. County of Green Lake, 157 F.3d 465, 473 (7th Cir. 1998) (quoting City of Revere v. Massachusetts Gen. Hosp., 463 U.S. 239, 244 (1983)).

Two problems exist with Williams' Complaint. First, Williams has not sued a proper party Defendant. Williams has filed this suit under 42 U.S.C. § 1983. Section "1983 applies only to a person' who acts under color of state law." Dye v. Wargo, 253 F.3d 296, 299 (7th Cir. 2001). The "Sangamon County Jail" is not a "person" that may be sued under § 1983. Wright v. Porter County, 2013 WL 1176199, *2 (N.D. Ind. Mar. 19, 2013)("Wright also sues the jail itself, but this is a building, not a person' or even a policy-making body ...


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