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Jones v. Doe

United States District Court, S.D. Illinois

June 18, 2019

WILLIAM E. JONES, Y36585, Plaintiff,
v.
JOHN DOE 1 and JANE DOE 1, Defendants.

          MEMORANDUM & ORDER

          J. PHIL GILBERT UNITED STATES DISTRICT JUDGE

         Plaintiff William Jones[1] filed an Amended Complaint pursuant to 42 U.S.C. § 1983 for deprivations of his constitutional rights at Jefferson County Justice Center in Mount Vernon, Illinois. (Doc. 10). Plaintiff allegedly sustained head and neck injuries while being transported without a seatbelt by an unknown officer (“John Doe 1”) in January 2018. (Id. at p. 6). He was denied medical care for his injuries by an unknown nurse (“Jane Doe 1”). (Id.). Plaintiff seeks money damages against both defendants. (Id.).

         The Amended Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Amended Complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009).

         Amended Complaint

         Plaintiff makes the following allegations in the Amended Complaint (Doc. 10, p. 6): Plaintiff sustained head and neck injuries while being transported from Jefferson County Courthouse to Jefferson County Justice Center in January 2018. An unknown officer (“John Doe 1”) disregarded his request for a seatbelt and transported him in “shackles” and in a manner that caused him to slide across the seat and land on top of another inmate. Plaintiff hit his head, heard his neck crack, and lost all mobility. (Id.). He requested immediate medical treatment at a hospital. (Id. at p. 6). An unknown nurse (“Jane Doe 1”) from Jefferson County Justice Center visually examined him while he was still in the vehicle. She told Officer John Doe 1 that Plaintiff was “faking it” and ordered him to get out of the vehicle. Once “feeling returned, ” Plaintiff complied with the order. However, his request for hospital treatment was denied, and a doctor did not examine him for more than a week. The doctor prescribed Tylenol for pain, a low bunk permit, and an extra mattress. Plaintiff was denied all other medical testing and treatment. (Id.).

         Based on the allegations in the Amended Complaint, the Court finds it convenient to reorganize the pro se action into the following enumerated Counts:

Count 1: John Doe 1 violated Plaintiff's constitutional rights by transporting him from court to Jefferson County Justice Center in shackles, without a seatbelt, and in a manner that caused bodily injury.
Count 2: Jane Doe 1 violated Plaintiff's constitutional rights by denying him adequate and timely medical treatment for his head injury, neck injury, and loss of mobility that occurred during his transport from court to Jefferson County Justice Center in January 2018.

         Any other claim that is mentioned in the Amended Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.[2]

         Discussion

         The legal framework applicable to both claims depends on Plaintiff's status as an arrestee, detainee, or convicted person. The Fourth Amendment “governs the period of confinement between arrest without a warrant and the [probable cause determination]” and triggers an “objectively reasonable” standard for searches and seizures. Currie v. Chhabra, 728 F.3d 626, 629 (7th Cir. 2013) (quoting Villanova v. Abrams, 972 F.2d 792, 797 (7th Cir. 1992)). The Fourteenth Amendment Due Process Clause governs claims of pretrial detainees and prohibits all forms of punishment. Klebanowski v. Sheahan, 540 F.3d 633, 637 (7th Cir. 2008). Finally, the Eighth Amendment governs claims of convicted persons and prohibits punishment that is cruel and unusual. Id.

         It is unclear whether Plaintiff was an arrestee, pretrial detainee, or convicted person when his claims arose, but this can be sorted out in time. Courts considering claims brought by arrestees, pretrial detainees, and convicted persons have allowed them to proceed where the failure to provide seatbelts was accompanied by the intentional or reckless driving of the defendant. See, e.g., Edwards v. David, 2017 WL 2653077 (N.D. Ill. 2017) (Fourth Amendment claim allowed to proceed against officer who refused to seatbelt arrestee, drove recklessly through a construction zone, and caused bodily injury); Brown v. Fortner, 518 F.3d 552 (8th Cir. 2008) (Eighth Amendment claim allowed to proceed against driver who refused to fasten convicted person's seatbelt, drove at an excessive speed, crossed double-yellow lines, and followed vehicles too closely). The allegations that Plaintiff was cuffed, denied a seatbelt, and subjected to reckless driving resulting in injuries are sufficient to support a claim against Officer John Doe 1.

         The allegations also support a claim against Nurse Jane Doe 1 for denying Plaintiff's requests for medical treatment following the incident in January 2018. He suffered head and neck injuries that rendered him immobile, at least temporarily, and caused continuing pain. At this stage, the Court cannot dismiss Count 2 against Nurse Jane Doe 1.

         Identification of ...


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