United States District Court, S.D. Illinois
WILLIAM E. JONES, Y36585, Plaintiff,
JOHN DOE 1 and JANE DOE 1, Defendants.
MEMORANDUM & ORDER
PHIL GILBERT UNITED STATES DISTRICT JUDGE
William Jones 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
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).
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.).
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.
other claim that is mentioned in the Amended Complaint but
not addressed herein is considered dismissed without
prejudice as inadequately pled under
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.
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.
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.