United States District Court, N.D. Illinois, Eastern Division
MEMORANDUM OPINION AND ORDER
AMY J. ST. EVE, District Judge.
On March 25, 2014, Plaintiff Cesar Maldonado brought a three-count First Amended Complaint against Defendants Thomas J. Dart, Sheriff of Cook County, Correctional Officer Esteban Garcia, Superintendent Robert Lyles, Jr., and Executive Director Gary Hickerson alleging a Fourteenth Amendment due process deliberate indifference claim based on Defendant Officer Garcia's failure to protect (Count I), a failure to train claim against Defendant Officers Lyles, Hickerson, and Sheriff Dart pursuant to Monell v. Department of Soc. Servs., 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978) (Count II), and an indemnification claim under 745 ILCS 10/9-102 against Cook County (Count III).
Before the Court is Defendants' motion for summary judgment brought pursuant to Federal Rule of Civil Procedure 56(a) and Defendants' motion to strike Plaintiff's Northern District of Illinois Local Rule 56.1(b)(3) Response. For the following reasons, the Court grants Defendants' summary judgment motion and dismisses this lawsuit in its entirety. Further, the Court denies Defendants' motion to strike Plaintiff's Rule 56.1(b)(3) Response as moot because the Court considered Defendants' arguments within the context of each challenged fact.
I. Northern District of Illinois Local Rule 56.1
Local Rule 56.1 "is designed, in part, to aid the district court, which does not have the advantage of the parties' familiarity with the record and often cannot afford to spend the time combing the record to locate the relevant information, ' in determining whether a trial is necessary." Delapaz v. Richardson, 634 F.3d 895, 899 (7th Cir. 2011) (citation omitted). Local Rule 56.1(a) requires the moving party to provide "a statement of material facts as to which the moving party contends there is no genuine issue and that entitle the moving party to a judgment as a matter of law." Petty v. City of Chicago, 754 F.3d 416, 420 (7th Cir. 2014). "The non-moving party must file a response to the moving party's statement, and, in the case of any disagreement, cite specific references to the affidavits, parts of the record, and other supporting materials relied upon.'" Id. (citation omitted); see also L.R. 56.1(b)(3)(A). Local Rule 56.1(b)(3)(C) "requires specifically that a litigant seeking to oppose a motion for summary judgment file a response that contains a separate statement... of any additional facts that require the denial of summary judgment.'" Sojka v. Bovis Lend Lease, Inc., 686 F.3d 394, 398 (7th Cir. 2012) (citation omitted).
In general, the purpose of Local Rule 56.1 statements and responses is to identify the relevant admissible evidence supporting the material facts, not to make factual or legal arguments. See Cady v. Sheahan, 467 F.3d 1057, 1060 (7th Cir. 2006) ("statement of material facts did  not comply with Rule 56.1 as it failed to adequately cite the record and was filled with irrelevant information, legal arguments, and conjecture"). "When a responding party's statement fails to dispute the facts set forth in the moving party's statement in the manner dictated by the rule, those facts are deemed admitted for purposes of the motion." Cracco v. Vitran Exp., Inc., 559 F.3d 625, 632 (7th Cir. 2009). Also, the Court will not consider the additional facts set forth in Plaintiff's Rule 56.1(b)(3)(A) Response because any such facts must be in his Rule 56.1(b)(3)(C) Statement of Additional Facts. See Ciomber v. Cooperative Plus, Inc., 527 F.3d 635, 643-44 (7th Cir. 2008); see also Sojka, 686 F.3d at 398. With these standards in mind, the Court turns to the relevant facts underlying this lawsuit.
II. Relevant Facts
During the relevant time period, Maldonado was a pretrial detainee assigned to Division V, Tier 2-J at the Cook County Jail ("CCJ"), which houses medium-level classified detainees. (R. 31, Defs.' Rule 56.1 Stmt. Facts ¶ 5.) The September 25, 2012, incident underlying this lawsuit involves another detainee, Romain Oatis, who attacked Maldonado causing serious injury. (R. 44, Pl.'s Rule 56.1 Stmt. Add'l Facts ¶¶ 3, 4, 43.) As a result of the attack, Maldonado was in a coma for five days and suffered severe head trauma making it necessary for doctors to remove part of his skull to relieve the pressure in his brain. ( Id. ¶ 43.) Maldonado has a speech impediment, headaches, and memory loss resulting from the attack. ( Id. )
On September 25, 2012, Maldonado left Tier 2-J in the morning and went to the law library with several other detainees. (Defs.' Stmt. Facts ¶ 8.) Once Maldonado returned from the library, Defendant Officer Garcia took him to the day room, although Officer Garcia was supposed to transport Maldonado to his cell on Tier 2-J, which is on the upper deck. ( Id. ¶ 11; Pl.'s Stmt. Facts ¶ 6.) Officer Garcia took Maldonado to the day room because Officer Garcia did not have the necessary back-up to take Maldonado to his cell. (Pl.'s Stmt. Facts ¶ 7.)
At the time Officer Garcia took Maldonado back to the day room, detainees from the lower deck were there. ( Id. ¶ 10.) Pursuant to CCJ policy, detainees from the lower and upper decks are not allowed in the day room at the same time due to safety and efficiency concerns. ( Id. ¶ 5; Defs.' Stmt. Facts ¶ 56.) Once Maldonado entered the day room, he had words with Oatis, after which the confrontation between them escalated. (Defs.' Stmt. Facts ¶¶ 29-30.) At the end of the fight, Maldonado was unconscious. ( Id. ¶ 37.) A correctional officer then called an emergency "10-10, " after which several other correctional officers responded and medical staff arrived. ( Id. ¶¶ 41, 46, 47.)
SUMMARY JUDGMENT STANDARD
Summary judgment is appropriate "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a). A genuine dispute as to any material fact exists if "the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 2510, 91 L.Ed.2d 202 (1986). In determining summary judgment motions, "facts must be viewed in the light most favorable to the nonmoving party only if there is a genuine' dispute as to those facts." Scott v. Harris, 550 U.S. 372, 380, 127 S.Ct. 1769, 167 L.Ed.2d 686 (2007). The party seeking summary judgment has the burden of establishing that there is no genuine dispute as to any material fact. See Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). After "a properly supported motion for summary judgment is made, the adverse party must set forth specific facts showing that there is a genuine issue for trial.'" Anderson, 477 U.S. at 255 (quotation ...