Steven Murphy v. Anthony Wills, Caly Smith, Brenden Garcia, and C/O Tyner

Summary

The court conducted preliminary screening under 28 U.S.C. § 1915A of Steven Murphy’s § 1983 complaint concerning alleged excessive force, denial of medical care, and retaliation at Menard Correctional Center. The court allowed the excessive-force, deliberate-indifference, and retaliation claims to proceed against Garcia, Tyner, and Smith, while dismissing Anthony Wills without prejudice for lack of personal involvement.

Holdings

1. The allegations that Garcia and Tyner sprayed Murphy with excessive amounts of mace without provocation and injured him were sufficient to state a colorable Eighth Amendment excessive-force claim at the preliminary-review stage.
2. The allegations that Garcia and Tyner denied Murphy medical treatment and a shower after spraying him with mace, causing blurred vision, were sufficient to state a deliberate-indifference claim.
3. Murphy sufficiently pleaded a First Amendment retaliation claim against Smith, Garcia, and Tyner based on allegations that they caused or carried out the mace attack in retaliation for his grievances and lawsuits.
4. Murphy failed to state a claim against Wills because the complaint alleged no personal involvement by Wills and sought to impose liability based only on Wills's supervisory position and retention of Garcia.

Questions Presented

1. Whether the allegations that Garcia and Tyner repeatedly sprayed Murphy with mace without provocation stated an Eighth Amendment excessive-force claim.
2. Whether the allegations that Garcia and Tyner denied Murphy medical treatment and a shower after the mace exposure stated an Eighth Amendment deliberate-indifference claim.
3. Whether the allegations that Smith, Garcia, and Tyner attacked Murphy in response to his grievances and lawsuits stated a First Amendment retaliation claim.
4. Whether Murphy stated a § 1983 claim against Wills based solely on Wills's retention of Garcia as a staff member.

Disposition

other