Davenport v. Brammeier, et al.

Summary

The United States District Court for the Southern District of Illinois conducts a preliminary screening under 28 U.S.C. § 1915A of Justin M. Davenport's § 1983 complaint concerning alleged deliberate indifference to mental health needs, excessive force, and disciplinary proceedings. The court allows Eighth Amendment claims against several defendants to proceed, dismisses the disciplinary due process claim and certain defendants without prejudice, and dismisses official-capacity damages claims without prejudice.

Holdings

1. Davenport stated a colorable Eighth Amendment claim against Brammeier, Maddox, Shemonia, Ms. B., and Szopinski because the allegations plausibly showed an objectively serious suicidal condition and deliberate indifference to a substantial risk of self-harm.
2. Davenport stated colorable excessive-force claims against Robertson and Miracle based on allegations that Robertson used an entire can of pepper spray during the suicide attempt and Miracle beat and choked Davenport with a riot shield and rope.
3. Davenport failed to state a colorable due-process claim against Shemonia, Little, or Barwick because he did not allege facts showing a protected liberty interest or constitutionally deficient procedures, and his admission that he destroyed the bedsheet supplied some evidence supporting the disciplinary finding.
4. Davenport's claims for monetary damages against the defendants in their official capacities could not proceed and were dismissed without prejudice.

Questions Presented

1. Whether the allegations plausibly stated an Eighth Amendment deliberate-indifference claim against officials who allegedly failed to summon or provide mental-health assistance while Davenport was suicidal.
2. Whether the allegations plausibly stated an Eighth Amendment excessive-force claim based on the use of pepper spray, a riot shield, and a rope during Davenport's suicide attempt.
3. Whether Davenport stated a Fourteenth Amendment due-process claim based on a disciplinary ticket and punishment for destroying property during a suicide attempt.
4. Whether Davenport could pursue monetary damages against the defendants in their official capacities.

Disposition

other