Eddie Love v. Pulaski County Sheriff Department Jail, Lateia Martin, and Jane Doe

Summary

The United States District Court for the Southern District of Illinois screened Eddie Love’s 42 U.S.C. § 1983 complaint alleging repeated sexual assault by a detention-center officer. The court allowed the Eighth and Fourteenth Amendment claim to proceed against Officer Lateia Martin, dismissed the claims against the Pulaski County Sheriff’s Department Jail and Jane Doe without prejudice, and directed service of the complaint on Martin.

Holdings

1. A complaint does not state a claim against a defendant merely by naming that defendant without alleging the defendant's involvement in the constitutional deprivation. Because Love alleged no facts against Pulaski County Sheriff Department Jail or Jane Doe, the claims against them were dismissed without prejudice.
2. Love's allegations that Officer Martin kissed him and repeatedly fondled his genitals while he was restrained plausibly stated an Eighth or Fourteenth Amendment claim, so Count 1 survived preliminary review against Martin.

Questions Presented

1. Whether the complaint stated a plausible Eighth or Fourteenth Amendment claim against Officer Lateia Martin based on alleged sexual assault of a restrained detainee or prisoner.
2. Whether the complaint stated a claim against Pulaski County Sheriff Department Jail and Jane Doe when it alleged no facts describing their involvement in the constitutional deprivation.

Disposition

other