Londale Madison v. Anthony Wills, et al.

Summary

The United States District Court for the Southern District of Illinois conducts preliminary review under 28 U.S.C. § 1915A of Londale Madison’s § 1983 complaint concerning alleged failure to protect him from sexual assault by a cellmate. The court dismisses claims concerning confiscated documents and Fourth and Fourteenth Amendment theories, while allowing an Eighth Amendment failure-to-protect claim to proceed against the named correctional officials. The court also addresses service, identification of John Doe defendants, protective-order procedures, and motions filed by the plaintiff’s jailhouse lawyer.

Holdings

1. The complaint plausibly alleged that Madison faced a substantial risk of serious harm, that the defendants had actual knowledge of the risk, and that they failed to act; Count 1 therefore proceeds against Wills, Reichert, Klausie, Tyner, Knight, John Doe 1, and John Doe 2.
2. The failure-to-protect claim is analyzed under the Eighth Amendment, and Madison's claims under the Fourth and Fourteenth Amendments were dismissed.
3. The complaint did not plausibly state a separate claim against Wills based on an allegedly pre-approved prison-wide policy or practice because it alleged only Madison's personal experience and conclusory assertions.
4. Any claim based on the confiscation of Madison's original complaint, exhibits, letters, or grievances was dismissed because the alleged conduct was not attributed to any named defendant.
5. A non-lawyer jailhouse lawyer may not represent another person in federal court, assert another inmate's rights, or file or sign papers on another inmate's behalf.

Questions Presented

1. Whether Madison plausibly stated an Eighth Amendment failure-to-protect claim against the prison officials and officers.
2. Whether the complaint plausibly stated a claim against Warden Wills based on an alleged prison policy or practice.
3. Whether the alleged confiscation of litigation documents stated a claim against the named defendants.
4. Whether the alleged failure to protect should be analyzed under the Fourth or Fourteenth Amendments rather than the Eighth Amendment.
5. Whether Madison's motions concerning confiscated exhibits and assistance or representation by a jailhouse lawyer should be granted.

Disposition

other