Jonathan Johnston v. Regina Bosie, et al.

Summary

The United States District Court for the Central District of Illinois dismissed Jonathan Johnston’s pro se prisoner civil-rights complaint without prejudice after screening under 28 U.S.C. § 1915A. The court found pleading, personal-involvement, joinder, venue, and exhaustion issues, and concluded that the allegations concerning the MSR term and sex-offender programming did not state federal claims. Johnston was granted 35 days to seek leave to amend, with possible severance and transfer of claims concerning medical care at Menard Correctional Center.

Holdings

1. The complaint failed to satisfy Rule 8 because, aside from allegations concerning Nancy Jacoby and Prisoner Review Board member Regina Bosie, it did not adequately allege the direct personal involvement of the named individual defendants; correctional facilities themselves could not be sued for individual wrongdoing.
2. The complaint improperly combined unrelated claims concerning MSR, medical care, and prison programming against unrelated defendants and therefore did not comply with Rules 18 and 20; unrelated claims may need to proceed in separate lawsuits.
3. Johnston did not state a § 1983 claim challenging the recalculation or enforcement of his mandatory supervised release term because the claim challenged the fact or duration of confinement and therefore had to be pursued through state mandamus proceedings and, if necessary, federal habeas corpus rather than § 1983.
4. The aneurysm allegations, as pleaded, did not appear to state a claim because Johnston alleged no resulting harm or injury from the delayed assessment and medication interruption and did not identify any responsible individual; the court nevertheless permitted him to attempt amendment.
5. The lung-care allegations might be amended to state a claim, but Johnston needed to identify the responsible Taylorville or Vandalia personnel, clarify the relevant periods of confinement, and address administrative exhaustion.
6. The allegations concerning denial of sex-offender treatment programming did not state a federal claim because there is no constitutional right to participate in prison programming to earn good-time credit, and the allegations indicated that Johnston was found not to need or qualify for the program.

Questions Presented

1. Whether the complaint satisfied Federal Rule of Civil Procedure 8 and adequately alleged the personal involvement of each defendant.
2. Whether the complaint improperly joined unrelated claims against unrelated defendants under Federal Rules of Civil Procedure 18 and 20.
3. Whether the challenge to the recalculation of Johnston's mandatory supervised release term stated a claim under 42 U.S.C. § 1983.
4. Whether the allegations concerning aneurysm care, lung-nodule care, and sex-offender treatment programming stated federal claims.
5. Whether dismissal without prejudice with an opportunity to amend was appropriate.

Disposition

dismissed