United States District Court, S.D. Illinois
MEMORANDUM AND ORDER
J. ROSENSTENGEL United States District Judge.
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
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).
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.).
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
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
Count 2: Access to courts claim against
Defendants Clinton County Jail and United States Marshals
explained below, neither of these counts shall be allowed to
proceed beyond screening.
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.
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 ...