Corey Williams v. Jeremiah Brown, Sergeant Belcher, Jane Doe Fitzgerald, and John Doe #s 1-11

Summary

The United States District Court for the Southern District of Illinois conducted preliminary screening under 28 U.S.C. § 1915A of Corey Williams’s prisoner civil rights complaint arising from an alleged use of excessive force at Lawrence Correctional Center. The court allowed Eighth Amendment excessive-force and Illinois assault-and-battery claims to proceed against John Doe Officers 1–7, and a deliberate-indifference-to-medical-needs claim to proceed against John Doe Officers 2–6 and 8. Claims against Jeremiah Brown, Sergeant Belcher, Counselor Fitzgerald, John Does 9–11, and unspecified officers were dismissed without prejudice; Brown was added in his official capacity solely to facilitate discovery identifying the John Doe defendants.

Holdings

1. The complaint plausibly stated an Eighth Amendment excessive-force claim against John Doe officers 1 through 7, so Count 1 could proceed.
2. The complaint plausibly stated Illinois assault and battery claims against John Doe officers 1 through 7, and those claims could proceed as Count 2.
3. The complaint plausibly stated an Eighth Amendment deliberate-indifference claim against John Doe officers 2 through 6 and 8 for failing to obtain medical care, so Count 3 could proceed.
4. Claims against additional unidentified officers, John Does 9 through 11, Counselor Fitzgerald, and Sergeant Belcher were dismissed without prejudice because the complaint did not sufficiently connect those defendants to a constitutional violation.

Questions Presented

1. Whether the complaint plausibly stated an Eighth Amendment excessive-force claim against John Doe officers 1 through 7.
2. Whether the complaint plausibly stated Illinois assault and battery claims arising from the same alleged use of force.
3. Whether the complaint plausibly stated an Eighth Amendment deliberate-indifference-to-medical-needs claim against John Doe officers 2 through 6 and 8.
4. Whether the claims against unidentified officers, John Does 9 through 11, Counselor Fitzgerald, and Sergeant Belcher were sufficiently pleaded to proceed.
5. Whether the current warden could be added in his official capacity solely to facilitate discovery identifying the John Doe defendants.

Disposition

other