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Mabie v. Kyle

United States District Court, S.D. Illinois

September 21, 2016

WILLIAM MABIE, Plaintiff,
v.
OFFICER KYLE, CLINTON CNTY. JAIL, and U.S. MARSHALS SERV., Defendants.

          MEMORANDUM AND ORDER

          NANCY J. ROSENSTENGEL United States District Judge.

         Plaintiff William Mabie, a pretrial detainee at the Clinton County Jail, brings this pro se action for alleged violations of his constitutional rights under 42 U.S.C. § 1983 and Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) (Doc. 11). Mabie's initial complaint was dismissed for failure to state a claim, his motion to reconsider was granted because he was improperly assessed a strike without an opportunity to amend, and he ultimately filed an amended complaint. Mabie alleges that United States Marshals Service and Clinton County Jail personnel were deliberately indifferent to his medical needs by denying or delaying access to medication and eyewear (Doc. 11). He also alleges that the parties obstructed his access to the courts by preventing him from purchasing stamps. In conjunction with his claims, Mabie named Officer Kyle, the Clinton County Jail, and the United States Marshals Service. He seeks monetary compensation.

         This case is now before the Court for a preliminary review of the Complaint pursuant to 28 U.S.C. § 1915A. Under Section 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).

         The Complaint

         Mabie alleges that when he arrived in the custody of the Clinton County Jail on a writ he was not given his prescription medications or the eyewear (contacts or glasses) that he needed to see properly (Doc. 11 at 5, 7). Mabie attributes the deprivation of these medical necessities to Officer Kyle of the Clinton County Jail, as well as federal authorities at large-namely the Bureau of Prisons and the United States Marshals Service (Id.). Mabie claims that he asked the BOP and the Marshals Service to forward his medical information, but that they did not do so (Id.). He speculates that the failure to forward his medical information was an attempt to frustrate his ability to participate in his underlying criminal case (Id.). He alleges that finally in February 2016, the United States District Judge presiding over his criminal case ordered the Marshals to retrieve his glasses (Id.). Around this time, he also was allowed to see a doctor to get updates on his prescriptions and other medical needs (Id.). Mabie does not allege that he suffered any lasting harm from the lack of access to medications and eyewear, though he does allege that during the time when he was without these items he was in pain and could not read (Id.).

         In addition to his complaints about medical care, Mabie also alleges that the United States Marshals and the Clinton County Jail denied him access to the courts by preventing him from getting any stamps to send legal mail (Id.). According to Mabie, he had to trade food to get stamps (Id.).

         Discussion

         Based on the allegations, the Court finds it convenient to divide the pro se Complaint into the following enumerated claims. 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. The designation of these counts does not constitute an opinion regarding their merit.

Count 1: Eighth Amendment claim against Defendants Officer Kyle, Clinton County Jail, and the United States Marshals Service for delaying or denying access to medical care for Mabie's prescription medications and eyewear; and
Count 2: Access to courts claim against Defendants Clinton County Jail and United States Marshals Service.

         As explained below, neither of these counts shall be allowed to proceed beyond screening.

         As an initial matter, Mabie is a pretrial detainee, so he is not yet eligible to bring claims under the Eighth Amendment. The Seventh Circuit has found that claims by pretrial detainees may be assessed under the Fourteenth Amendment, however, and that it is “convenient and entirely appropriate to apply the same standard to claims arising under the Fourteenth Amendment (detainees) and the Eighth Amendment (convicted prisoners) without differentiation.” See Board v. Farnham, 394 F.3d 469, 478 (7th Cir. 2005) (internal citation omitted). Accordingly, the following discussion will analyze Mabie's claims in light of the standards applicable to comparable Eighth Amendment claims.

         Count 1

         The Eighth Amendment to the United States Constitution protects prisoners from cruel and unusual punishment. U.S. Const., amend. VIII; see also Berry v. Peterman, 604 F.3d 435 (7th Cir. 2010). Prison conditions that deprive inmates of basic human needs, such as inadequate nutrition, health, or safety, may constitute cruel and unusual punishment. Rhodes v. Chapman, 452 U.S. 337, 346 (1981); see also James v. Milwaukee Cnty., 956 F.2d 696, 699 (7th Cir. 1992). Prison officials violate the Eighth Amendment's proscription against cruel and unusual punishment when their conduct demonstrates deliberate indifference to the serious medical needs of an inmate. See Estelle v. Gamble, 429 U.S. 97, 104 (1976); Gutierrez v. Peters, 111 F.3d 1364, 1369 (7th Cir. 1997). To establish deliberate indifference to a medical condition, a prisoner must show a condition that is sufficiently serious (objective component) and that an official acted with a sufficiently culpable state of mind in failing to address the condition (subjective component). Id. Whether a condition is ...


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