Bobby Tatum v. Darren Galloway, John Does, Jane Does, Lt. Thomas, John Doe Officers, Jane Doe Nurse, Gregory D. Little, and Jacob Fletcher

Summary

The United States District Court for the Southern District of Illinois screened Bobby Tatum’s amended 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A. The court dismissed with prejudice the First Amendment retaliation claim concerning Tatum’s transfer to Pinckneyville Correctional Center, finding the allegations insufficient to establish retaliatory motive. The court severed the excessive force, deliberate indifference, retaliation, and due process claims involving events at Pinckneyville into a new case and directed the Clerk to close the original action.

Holdings

1. Tatum failed to state a First Amendment retaliation claim because he did not plausibly allege that his PREA complaint was a motivating factor in the transfer to Pinckneyville.
2. Counts 2 through 5 were improperly joined with Count 1 and were severed into a new case.
3. The claims against the John and Jane Doe transfer officers were inadequately pleaded because Tatum did not identify particular defendants or allege facts connecting any specific official to the retaliatory transfer.

Questions Presented

1. Whether Tatum stated a First Amendment retaliation claim based on his transfer to Pinckneyville Correctional Center after filing a PREA complaint.
2. Whether the claims arising from the alleged excessive force, denial of medical care, false disciplinary ticket, and disciplinary adjudication were improperly joined with the transfer-retaliation claim.
3. Whether the unidentified transfer officials were sufficiently specified to support claims against particular defendants.

Disposition

dismissed