Sanders v. Mearl J. Justice
| Decision Date | 16 March 2015 |
| Docket Number | Case No. 15-cv-00142-SMY |
| Court | U.S. District Court — Southern District of Illinois |
| Parties | RAMOS SANDERS, #S-02150, Plaintiff, v. MEARL J. JUSTICE, RICHARD WATSON, PHILLIP McLAURIN, THOMAS T. TRICE, OFFICER LEVI BRIDGES, and CAMRON REID, Defendants. |
Plaintiff Ramos Sanders, an inmate who is currently incarcerated at Menard Correctional Center ("Menard"), brings this action pursuant to 42 U.S.C. § 1983 against six jail officials in St. Clair County, Illinois (Doc. 1). In the complaint, Plaintiff claims that these officials subjected him to unconstitutional conditions of confinement from 2011 until 2013 (Doc. 1, pp. 7-9). He now seeks monetary damages against them (Doc. 1, p. 10).
This 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 isimmune from such relief. 28 U.S.C. § 1915A(b). The complaint survives threshold review under this standard.
According to the complaint, Plaintiff was housed at St. Clair County Jail ("Jail") for two years (Doc. 1, pp. 7-9). He was initially detained there for thirteen months between December 24, 2011, and January 24, 2013 (Doc. 1, p. 8). Plaintiff returned to the Jail in 20132 (Doc. 1, p. 7). Plaintiff claims that he was subjected to deplorable conditions at all times.
According to the complaint, Plaintiff was housed at the Jail for thirteen months following his arrest on December 24, 2011 (Doc. 1, p. 8). During that time, he was deprived of basic human necessities, such as clean living conditions, a nutritionally adequate diet, adequate hygiene supplies, and ample exercise opportunities. The food was prepared in unsanitary conditions, allowing for contamination (Doc. 1, p. 9). Cleaning supplies were denied, and two of Plaintiff's cellmates in his four-person cell contracted scabies.3 Plaintiff was also denied access to exercise opportunities outside of his cell for two years because the gym was used to house inmates and a Jail policy prohibited exercise anywhere else. Sergeant Camron Reid and Officer Levi Bridges were allegedly responsible for maintaining safe and sanitary conditions at the Jail during this time period, and they failed to respond to Plaintiff's complaints.
Plaintiff returned to the Jail at some point in 2013. During his second period of confinement there, Plaintiff contracted a bacterial stomach infection that resulted from the regular consumption of food that was contaminated with rat feces. For three months,Plaintiff endured "extreme stomach pain, diarrhea, frequent bowel movements, upset stomach, vomitting (sic), cold sweats, and weight loss" (Doc. 1, p. 7).
He submitted sick call slips for a month, but was not scheduled for an appointment with a doctor. When he complained to a nurse, she met with him immediately. Together, they discussed the possibility of food contamination after reviewing Plaintiff's symptoms and discovering his fifty-five pound weight loss. The nurse indicated that Plaintiff's weight would be checked twice each week, and he would be scheduled for an appointment with Doctor Larson.
Another two months passed before Plaintiff met with Doctor Larson. He promptly ran blood tests and diagnosed Plaintiff with a bacterial stomach infection (Doc. 1, pp. 7-8). Plaintiff was admitted to the Jail's medical unit, where he remained for two weeks while he was treated with three types of antibiotics. Plaintiff took the antibiotics for thirty days.4
Plaintiff attributes this bacterial infection to unsanitary conditions in the Jail's kitchen. He sues Sheriff Mearl Justus, Sheriff Richard Watson, Superintendent Phillip McLaurin, and Captain Thomas Trice for knowingly failing to train and supervise the Jail's kitchen staff in safe food preparation and sanitary kitchen conditions.
After carefully reviewing the allegations, the Court finds that the complaint articulates the following viable claims:
Count 1: Defendants Bridges and Reid subjected Plaintiff to unconstitutional conditions of confinement at the Jail by depriving him of clean living conditions, a nutritionally adequate diet, adequate hygiene supplies, and ample exercise opportunities from December 24, 2011, until January 24, 2013; Count 2: Defendants Justus, Watson, McLaurin, and Trice, while acting in their official capacities, subjected Plaintiff to unconstitutional conditions of confinement at the Jail by failing to train and supervise the Jail's kitchen staff as it relates to safe food preparation and sanitary kitchen conditions.
The applicable legal standard for these claims depends on Plaintiff's status as a pretrial detainee or inmate while he was housed at the Jail.5 The Due Process Clause of the Fourteenth Amendment governs claims of pretrial detainees, while the Eighth Amendment applies to claims of inmates. See Rice ex rel. Rice v. Corr. Med. Servs., 675 F.3d 650, 664 (7th Cir. 2012); Forest v. Prine, 620 F.3d 739, 744-45 (7th Cir. 2010); Klebanowski v. Sheahan, 540 F.3d 633, 637 (7th Cir. 2008). Regardless, the Seventh Circuit has made it clear that Eighth Amendment and Fourteenth Amendment case law can be used interchangeably in this context. Id.
Claims that relate to the conditions of confinement generally fall under the "cruel and unusual punishment" clause of the Eighth Amendment. All Eighth Amendment claims have an objective and a subjective component. McNeil v. Lane, 16 F.3d 123, 124 (7th Cir. 1994); see also Wilson v. Seiter, 501 U.S. 294, 302 (1991). The objective analysis examines whether the conditions of confinement exceeded contemporary bounds of decency of a mature civilized society. Id. The conditions must result in unquestioned and serious deprivations of basic human needs or deprive inmates of the minimal civilized measure of life's necessities. Jamison-Bey v. Thieret, 867 F.2d 1046, 1048 (7th Cir. 1989); Meriwether v. Faulkner, 821 F.2d 408, 416 (7th Cir. 1987).
However, not all prison conditions trigger Eighth Amendment scrutiny—only deprivations of basic human needs like food, medical care, sanitation and physical safety.Rhodes v. Chapman, 452 U.S. 337, 346 (1981); see also James v. Milwaukee County, 956 F.2d 696, 699 (7th Cir. 1992). "Some conditions of confinement may establish an Eighth Amendment violation 'in combination' when each would not do so alone, but only when they have a mutually enforcing effect that produces the deprivation of a single, identifiable human need such as food, warmth, or exercise-for example, a low cell temperature at night combined with a failure to issue blankets." Wilson, 501 U.S. at 304.
The conditions described in the complaint support Counts 1 and 2. These conditions include the denial of cleaning supplies, exposure to contaminated food, and a two-year denial of exercise opportunities. Whether considered in isolation or in combination, the conditions satisfy the objective component of Plaintiff's claims. See, e.g., Delaney v. DeTella, 256 F.3d 679, 684 (7th Cir. 2001) (); Pearson v. Ramos, 237 F.3d 881, 884-85 (7th Cir. 2001) (); Turley v. Rednour, 729 F.3d 645, 652 (7th Cir. 2013) (). See also Sanders v. Sheahan, 198 F.3d 626 (7th Cir. 1999) (); Antonelli v. Sheahan, 81 F.3d 1422, 1432 (7th Cir. 1996) (); Johnson v. Pelker, 891 F.2d 136, 139-40 (7th Cir. 1989) ().
But the Court's analysis does not end there. In conditions of confinement cases, the relevant state of mind is deliberate indifference to inmate health or safety; the official must be aware of facts from which the inference could be drawn that a substantial risk of serious harmexists, and he or she also must draw the inference. See, e.g., Farmer v. Brennan, 511 U.S. 825, 837 (1994); Estelle v. Gamble, 429 U.S. 97, 104 (1976); Del Raine v. Williford, 32 F.3d 1024, 1032 (7th Cir. 1994).
With regard to Count 1, the complaint suggests that Defendants Bridges and Reid were deliberately indifferent to Plaintiff's living conditions. According to the complaint, both of these defendants were directly responsible for maintaining safe and clean conditions at the Jail during this time period, and both ignored Plaintiff's complaints about the conditions (Doc. 1, pp. 8-9). As a result, Plaintiff was deprived of safe food, a clean cell, and adequate exercise opportunities. These allegations support deliberate indifference claims against Defendants Bridges and Reid under Count 1.
With regard to Count 2, Plaintiff alleges that Defendants Justus, Watson, McLaurin, and Trice failed to train and supervise kitchen staff in the proper handling of food and sanitary conditions of the kitchen (Doc. 1, pp. 7-8). "[F]ailure to train claims are usually maintained against municipalities, not against individuals, and, in the Eighth Amendment context, such claims may only be maintained against a municipality." Brown v. Budz, 398 F.3d 904, 917 (7th Cir. 2005) (Sanville v. McCaughtry, 266 F.3d 724, 739-40 (7th Cir. 2001)). In this context, a "municipality may be directly liable for constitutional violations by its officers when the municipality...
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