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Watson v. ST. Clair County Jail

United States District Court, S.D. Illinois

June 24, 2019

JOHN WATSON, #B85426 Plaintiff,



         Plaintiff John Watson, who was an inmate in the Illinois Department of Corrections (“IDOC”) and is currently being held at the Beaumont Low Federal Correctional Institution in Beaumont, Texas, brings this action for deprivations of his constitutional rights pursuant to 42 U.S.C. § 1983 for events occurring at the St. Clair County Jail. He is seeking money damages and an order requiring the firing of the officers involved from their positions.[1] (Doc. 1, p. 7).

         The 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 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).

         The Complaint

         Plaintiff makes the following allegations: While in custody at St. Clair County Jail, sometime in the beginning of November 2018, Plaintiff was jumped and severely beaten. (Doc. 1, p. 5). Officer Lazante came and pulled plaintiff out of the cellblock ordering him to face the wall with his hands in the air. Id. Due to the severity of his injuries, Plaintiff was unable to comply, and so Lazante struck him in the face breaking his jaw. Id. Plaintiff was then taken to medical, where he was told to sit up straight on the examination table. Id. He repeatedly told Officer Jermane that he was unable to sit up and could not breath due to his injuries, but Jermane just repeated that he needed to sit up for his examination. Id. Words exchanged between Plaintiff and Jermane, and then Jermane struck him in the face. Id. After the nurse examined him, Plaintiff was put in an interview room for at least an hour waiting to go to the hospital. St. Clair County Jail did not send for an E.M.T., and instead drove him to the hospital in a squad car handcuffed and shackled. Id. At the hospital, the transport officer made him walk into the emergency room, even after Plaintiff told him it was too painful. Id. Plaintiff underwent emergency surgery to insert a tube in his lung, which had collapsed and was filling with blood. Id. at pp. 5-6. Plaintiff also had several broken ribs. Id. at p. 6. It was later determined that the trauma to his face was too severe for the local hospital, and so Plaintiff was transported to the trauma center at St. Louis University Hospital, where he had reconstructive surgery on his face. Id. The left side of his face had been crushed damaging his orbital socket, sinus plate, and jaw. Id. Plaintiff stayed in the intensive care unit for almost a week, and then remained at the St. Clair County Jail's infirmary for five months. Id.


         Based on the allegations of the Complaint, the Court finds it convenient to divide the pro se action into the following two Counts. The parties and the Court will use these designations in all future pleadings and orders, unless otherwise directed by this Court:

Count 1: Eighth Amendment claim of excessive force against Lazante and Jermane for physically assaulting Plaintiff resulting in extensive injuries.
Count 2: Eighth Amendment claim of deliberate indifference to serious medical needs against the St. Clair County Jail.

         Any claims that are not identified above should be considered dismissed without prejudice as inadequately pled under Twombly.[2]

         Applicable Legal Standard

         Before screening Plaintiff's constitutional claim, the Court must first consider what legal standard applies. The applicable legal standard for Plaintiff's claims depends on his status as a pretrial detainee or convicted prisoner during his detention at the jail. The Eighth Amendment standards for excessive force and medical deliberate indifference are applicable if Plaintiff was a convicted prisoner during the relevant time period. Wilkins v. Gaddy, 559 U.S. 34 (2010); Farmer v. Brennan, 511 U.S. 825, 834 (1994). On the other hand, if Plaintiff was a pretrial detainee, Plaintiff's claim is governed by the Fourteenth Amendment, whether the force used or the medical treatment provided was objectively unreasonable. Kingsley v. Hendrickson, 135 S.Ct. 2466 (2015); Miranda v. Cty Lake, 900 F.3d 335, 352 (7th Cir. 2018).

         The Complaint does not indicate whether Plaintiff was a pretrial detainee or a convicted prisoner at the time the alleged incidents of excessive force and medical indifference occurred. Regardless, the Complaint survives screening because the allegations support a constitutional claim under the most stringent of these standards, i.e., the Eighth Amendment. For purposes of this screening order, the Court looks to Eighth Amendment case law. Count 1 survives screening under this standard and the less stringent standards available to detainees. Accordingly, the Court need not resolve Plaintiff's legal status at this time.

         Coun ...

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