Deandre Bradley v. Ronald Hain, in his individual and official capacity; Kane County, Illinois; Rochelle Stockman, in her individual capacity; A. Keaty, in his individual capacity; S. McKanna, in his individual capacity; and Dr. Kul Sood, in his individual capacity

Summary

The United States District Court for the Northern District of Illinois addressed motions to dismiss claims brought by a disabled pretrial detainee concerning allegedly inadequate disability accommodations, medical care, and medications at the Kane County Adult Justice Center. The court allowed the plaintiff’s individual-capacity claims against Sheriff Ronald Hain and due process claims against Rochelle Stockman and Dr. Kul Sood to proceed. The court dismissed the equal protection claim against Stockman and Sood without prejudice and denied Hain’s motion to dismiss.

Holdings

1. Bradley sufficiently alleged at the pleading stage that Hain knew of or participated in systemic violations concerning the housing, treatment, and medical care of disabled detainees. The individual-capacity claims against Hain were therefore not dismissed.
2. Bradley adequately stated a due process claim against Stockman and Dr. Sood based on alleged denial or interruption of medical care and medications and based on delays in obtaining a proper mattress and wheelchair. That claim could proceed past the motion-to-dismiss stage.
3. Bradley failed to state an equal protection claim against Stockman and Dr. Sood because he did not plausibly allege that they treated him differently from non-disabled detainees or acted with discriminatory purpose. The claim was dismissed without prejudice.

Questions Presented

1. Whether Bradley adequately alleged Hain's personal involvement in the asserted constitutional violations to support individual-capacity liability under 42 U.S.C. § 1983.
2. Whether Bradley adequately pleaded a Fourteenth Amendment due process claim against Stockman and Dr. Sood based on inadequate medical care, medications, disability-management equipment, and delays in obtaining a proper mattress and wheelchair.
3. Whether Bradley adequately pleaded that Stockman and Dr. Sood treated him differently because of disability and acted with discriminatory purpose, as required for an equal protection claim.

Disposition

other