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Mathlock v. Fleming

United States District Court, N.D. Illinois, Eastern Division

July 3, 2019

Sylvia Mathlock, as mother and next friend of J.R., a minor, Plaintiff,
v.
Eric Fleming, Najuan Mack, Leonard Dixon, Office of the Chief Judge of the Circuit Court of Cook County, and County of Cook, Illinois, Defendants.

          MEMORANDUM OPINION AND ORDER

          MANISH S. SHAH UNITED STATES DISTRICT JUDGE

         While J.R. (a minor) was detained at the Cook County Juvenile Temporary Detention Center, defendants Eric Fleming and Najuan Mack aggressively handcuffed him, breaking his arm and causing other injuries. Sylvia Mathlock, J.R.'s mother, now brings 42 U.S.C. § 1983 and state-law claims on J.R.'s behalf. J.R. sues Fleming and Mack (both detention center employees), Superintendent Leonard Dixon, the Office of the Chief Judge, and Cook County. The Office of the Chief Judge and Cook County move to dismiss all claims against them, and Dixon moves to dismiss the § 1983 official-capacity claim against him. For the reasons discussed below, these motions are granted.

         I. Legal Standards

         A motion to dismiss under Rule 12(b)(6)[1] tests whether a complaint states a claim for which relief may be granted. Fed.R.Civ.P. 12(b)(6). A plaintiff's “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). In other words, a “complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.'” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). I draw all reasonable inferences in favor of the non-movant. Squires-Cannon v. Forest Preserve Dist. of Cook Cty., 897 F.3d 797, 802 (7th Cir. 2018).

         II. Background

         J.R., a fifteen-year-old boy, was detained at the Cook County Juvenile Temporary Detention Center. [1] ¶ 1.[2] Defendants Eric Fleming and Najuan Mack worked at the detention center, where they were members of the Rapid Response Team and responsible for ensuring safety and security. Id. ¶¶ 4-5. On July 19, 2018, Mack and Fleming aggressively handcuffed J.R., breaking his arm in the process. Id. ¶ 22. J.R. suffered extreme internal rotation of his arm, a displaced fracture of the surgical neck of his right humerus, and a broken humerus head. Id. ¶ 23. In addition to his physical pain and suffering, the incident caused J.R. emotional distress. Id. ¶ 24.

         Defendant Leonard Dixon was the superintendent at the time of the incident. Id. ¶ 6. As superintendent, Dixon oversaw, supervised, and directed all functions of the detention center. Id. ¶ 58. He was also the chief architect of its policies and was responsible for hiring, screening, training, retaining, supervising, and disciplining all detention center employees. Id. The Chief Judge of the Circuit Court of Cook County appointed Superintendent Dixon in May 2015. Id. ¶ 19. His appointment marked the end of a long transition period, during which administrative authority over the detention center was transferred from the Cook County Board to the Office of the Chief Judge. That transition began in 1999, when the ACLU filed a federal civil rights class action against Cook County alleging systemic mistreatment and neglect at the detention center. Id. ¶ 15. Eight years later, after determining that Cook County was not complying with the terms of the resulting settlement agreement, the district court appointed a transitional administrator to operate the detention center and bring it into compliance with the court's orders. Id. ¶ 16. The court also tasked the administrator with transitioning administrative authority over the detention center to the Office of the Chief Judge of the Circuit Court of Cook County. Id. A few months later, the Illinois legislature passed a similar bill, transferring administrative authority of the Cook County Juvenile Temporary Detention Center to the Office of the Chief Judge. Id. ¶ 17. The bill became effective January 1, 2008, though the detention center remained under control of the court's temporary administrator until 2015, when the court ordered that control be transferred to the Office of the Chief Judge. Id. ¶¶ 17-18.

         III. Analysis

         The Office of the Chief Judge and Cook County move to dismiss the § 1983 and respondeat superior claims, and Cook County asserts it is not a necessary party for indemnification purposes. Dixon moves to dismiss only the § 1983 claim against him in his official capacity.

         A. Section 1983

          The complaint alleges that the Office of the Chief Judge, Dixon, and Cook County are liable under a Monell theory for Mack's and Fleming's use of excessive force. More specifically, it alleges that the three government defendants failed to hire, train, and supervise detention center employees to prevent their unnecessary use of force. Defendants argue both that the Eleventh Amendment bars the § 1983 claim and that the complaint fails to allege a policy or practice as required to state a Monell claim.

         1. Eleventh Amendment Immunity

         Because the Eleventh Amendment bars suits against states but not against local governments, the parties' dispute centers on whether administering the Juvenile Temporary Detention Center is a state or county function.[3] (In Illinois, the Office of the Chief Judge is a state entity. See Drury v. McLean Cty., 89 Ill.2d 417, 427 (1982).) Defendants argue that the chief judge controls the detention center, making it an arm of the state and barring the § 1983 suit for damages. See Scott v. O'Grady, 975 F.2d 366, 369 (7th Cir. 1992) (noting that the Eleventh Amendment extends immunity to state officials sued in their official capacities). J.R. asserts that Cook County operates the detention center and that, therefore, the Eleventh Amendment does not bar his claims. J.R. does not dispute that as the superintendent, Dixon's actions represent official policy. See McMillian v. Monroe Cty., Ala., 520 U.S. 781, 785 (1997). In determining whether Dixon acted as an arm of the state, then, the relevant question is whether he is a final policymaker for Illinois or Cook County on the particular issue of hiring, training, and supervising detention center employees. Id. The question is not whether he is a state official “in some categorical ‘all or nothing' manner.” Id.

         Both the chief judge and the county manage different aspects of the detention center. To determine whether the detention center functions as an arm of the state for Eleventh Amendment purposes, I consider the extent of its financial autonomy from the state and its general legal status. Tucker v. Williams, 682 F.3d 654, 659 (7th Cir. 2012); Hess v. Port Auth. Trans-Hudson Corp., 513 U.S. 30, 47 (1994) (“When indicators of immunity point in different directions, the Eleventh Amendment's twin reasons for being remain our prime guide.”). The latter inquiry-the general legal status of the center-requires analyzing state law; though an official's ...


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