United States District Court, S.D. Illinois
MEMORANDUM AND ORDER
MICHAEL J. REAGAN, District Judge.
Plaintiff Esmond Sanford, a pretrial detainee at Madison County Jail ("Jail"), brings this civil rights action pursuant to 42 U.S.C. § 1983 (Doc. 1). Plaintiff claims, among other things, that Defendants have violated his rights under the Fourteenth Amendment by subjecting him to unhealthy and harmful conditions of confinement, denying him adequate access to the courts, and denying Muslims an equal opportunity to exercise their religion.
On May 19, 2014, Plaintiff filed the present complaint. (Doc. 1). Two days later, the Court entered an order (Doc. 5) directing Plaintiff to provide the Clerk of Court with documentation regarding his trust fund account statements. Either the Plaintiff misunderstood the Court's order or he never received it. Proceeding under the mistaken belief that the Court had never received the first complaint, Plaintiff filed another complaint, which was nearly identical to the first, on May 22, 2014. ( See Case No. 14-cv-00592-MJR, Doc. 1, filed May 22, 2014, S.D. Ill.). On June 13, 2014, the undersigned Judge entered an order in Case No. 14-cv-00592-MJR (Doc 5) consolidating the two cases and closing the later filed case without the assessment of a filing fee. Plaintiff's original complaint, the matter now under review, remains open.
Merits Review Under 28 U.S.C. § 1915A
Accordingly, this case is now before the Court for a preliminary review of the complaint pursuant to 28 U.S.C. § 1915A. Under § 1915A, the Court is required to promptly screen prisoner complaints to filter out nonmeritorious claims. 28 U.S.C. § 1915A(a). The Court is required to dismiss any portion of the complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief. 28 U.S.C. § 1915A(b).
An action or claim is frivolous if "it lacks an arguable basis either in law or in fact." Neitzke v. Williams, 490 U.S. 319, 325 (1989). 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." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). The claim of entitlement to relief must cross "the line between possibility and plausibility." Id. at 557. Conversely, a complaint is plausible on its face "when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Although the Court is obligated to accept factual allegations as true, see Smith v. Peters, 631 F.3d 418, 419 (7th Cir. 2011), some factual allegations may be so sketchy or implausible that they fail to provide sufficient notice of a plaintiff's claim. Brooks v. Ross, 578 F.3d 574, 581 (7th Cir. 2009). Additionally, Courts "should not accept as adequate abstract recitations of the elements of a cause of action or conclusory legal statements." Id. At the same time, however, the factual allegations of a pro se complaint are to be liberally construed. See Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). Upon careful review of the complaint, the Court finds that several of Plaintiff's claims against Defendants are subject to dismissal under § 1915A.
Legal Standard for Pre-trial Detainee Claims
Plaintiff, a pretrial detainee, is currently being held at the Madison County Jail. Plaintiff's claims therefore arise under the Due Process Clause of the Fourteenth Amendment. See Budd v. Motley, 711 F.3d 840, 842 (7th Cir. 2013) (citing Rice ex rel. Rice v. Corr. Med. Servs., 675 F.3d 650, 664 (7th Cir. 2012)). See also Klebanowski v. Sheahan, 540 F.3d 633, 637 (7th Cir. 2008). Although the Seventh Circuit has made it clear that pretrial detainees are afforded " at least as much protection as the constitution provides convicted prisoners, " the Seventh Circuit has also "found it convenient and entirely appropriate to apply the same standard to claims arising under the Fourteenth Amendment (detainees) and Eighth Amendment (convicted prisoners) without differentiation.'" Board v. Farnham, 394 F.3d 469, 478 (7th Cir. 2005) (emphasis in original) (quoting Henderson v. Sheahan, 196 F.3d 839, 845 n.2 (7th Cir. 1999) (citing Cavalieri v. Shepard, 321 F.3d 616, 620 (7th Cir. 2003)).
The Court finds it convenient to divide the complaint into five counts. 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.
Count 1: Conditions of confinement claim against Defendants for subjecting Plaintiff to conditions that amounted to cruel and unusual punishment
Plaintiff asserts a number of claims about the conditions of his confinement at the Madison County Jail. Specifically, he complains: on several occasions officers have insulted him (Doc. 1, ¶ 4); detainees went without hot water for two weeks when the hot water heater broke ( Id. ); detainees receive an unhealthy diet consisting of "1 hot meal a day, 1 honey bun and milk for breakfast, cold sandwiches and chips at night every night" ( Id. at ¶ 4); in order "to keep germs down" the jail keeps the temperature set at fifty degrees year round ( Id. at ¶ 6); and detainees are not allowed any recreational/exercise time year round ( Id. at ¶ 7).
Not all prison conditions trigger Eighth Amendment scrutiny - only deprivations of basic human needs like food, medical care, sanitation, and physical safety. Rhodes v. Chapman, 452 U.S. 337, 346 (1981); s ee also James v. Milwaukee Cnty., 956 F.2d 696, 699 (7th Cir. 1992). In order to prevail on a conditions of confinement claim, a plaintiff must allege facts that, if true, would satisfy the objective and subjective components applicable to all Eighth Amendment claims. McNeil v. Lane, 16 F.3d 123, 124 (7th Cir. 1994); see also Wilson v. Seiter, 501 U.S. 294, 302 (1991). The objective component focuses on the nature of the acts or practices alleged to constitute cruel and unusual punishment. Jackson v. Duckworth, 955 F.2d 21, 22 (7th Cir. 1992). The objective analysis examines whether the conditions of confinement exceed contemporary bounds of decency of a mature civilized society. Id. The condition must result in unquestioned and serious deprivations of basic human needs or deprive inmates of the minimal civilized measure of life's necessities. Rhodes, 452 U.S. at 347; accord Jamison-Bey v. Thieret, 867 F.2d 1046, 1048 (7th Cir. 1989); Meriwether v. Faulkner, 821 F.2d 408, 416 (7th Cir. 1987).
In addition to showing objectively serious conditions, a plaintiff must also demonstrate the subjective component to an Eighth Amendment claim. The subjective component requires that a prison official had a sufficiently culpable state of mind. Wilson, 501 U.S. at 298; see also McNeil v. Lane, 16 F.3d 123, 124 (7th Cir. 1994). In conditions of confinement cases, the relevant state of mind is deliberate indifference to inmate health or safety; the official must be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he also must draw the inference. See, e.g., Farmer v. ...