Michael Hendricks v. Livingston County et al.

Summary

The United States District Court for the Central District of Illinois screened Michael Hendricks’s complaint concerning alleged denial of personal possession of glucose tablets while detained at the Livingston County Jail. The court dismissed the complaint under 28 U.S.C. § 1915A(b)(1) for failure to state a claim, while granting leave to amend within thirty days, and denied the motion for injunctive relief. The court found insufficient allegations of personal involvement, grievance-related liability, or a policy or custom supporting liability against the corporate medical provider.

Holdings

1. The complaint failed to state a plausible constitutional claim because it did not identify which defendant denied Hendricks possession of glucose tablets and did not allege facts showing that the named defendants purposefully, knowingly, or recklessly engaged in objectively unreasonable medical care.
2. The alleged failure of Draper and Harmon to respond to Hendricks's grievances did not state a federal due-process violation.
3. The complaint failed to state a § 1983 claim against Turn Key Medical because it did not allege that an official policy, widespread practice or custom, or final policymaker caused the alleged constitutional deprivation.
4. Hendricks was not entitled to injunctive relief because the motion concerned allegations not included in the complaint and, in any event, he had not stated a plausible underlying constitutional claim.

Questions Presented

1. Whether the complaint plausibly alleged that any individual defendant violated Hendricks's Fourteenth Amendment right to objectively reasonable medical care.
2. Whether the allegations against Turn Key Medical supported § 1983 liability based on an official policy, widespread practice or custom, or policymaker action.
3. Whether the alleged failure of jail officials to respond to grievances stated a federal due-process claim.
4. Whether Hendricks was entitled to preliminary or mandatory injunctive relief.

Disposition

dismissed