Daniel Aguilar v. Janella Gaston-Camara
2017 U.S. App. LEXIS 11492
| 7th Cir. | 2017Background
- Aguilar, convicted in 1996, was released on parole (pre-2000 offenses) but DOC staff mistakenly treated him as an extended-supervision offender and imposed a 90-day detention without a hearing after he admitted supervision violations.
- DOC forms initially and at points properly identified him as on parole, but the Order to Detain and sanction forms checked “Extended Supervision.” Regional staff Gaston-Camara, Haessig, and Yeates recommended and approved the 90-day sanction; Donna Harris was an assistant regional chief for a different region (Region 7).
- Aguilar’s counsel (Saldana) contacted DOC staff about the sanction start date and, according to Aguilar, questioned the classification; DOC staff recall only discussions about sanction dates and produced an email about procedures.
- Aguilar sued under 42 U.S.C. § 1983 alleging Due Process and Eighth Amendment violations arising from misclassification and confinement without required parole procedures; defendants moved for summary judgment.
- The district court granted summary judgment for defendants; the Seventh Circuit affirmed, concluding Aguilar failed to present admissible evidence that any defendant was deliberately indifferent or actually aware of the misclassification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether misclassification and confinement without parole procedures violated Due Process | Misclassification deprived Aguilar of parole-specific procedural protections; DOC acted unlawfully by refusing to correct status | Defendants lacked knowledge of misclassification; at most negligent error, not a constitutional violation | Summary judgment for defendants; negligence insufficient for Due Process claim |
| Whether defendants violated the Eighth Amendment by subjecting Aguilar to punitive confinement without justification | Confinement under extended-supervision sanction (90 days) was punishment imposed with disregard for constitutional protections | No evidence defendants acted with deliberate indifference or knew of the misclassification; actions were at most negligent | Summary judgment for defendants; deliberate indifference not shown, Eighth Amendment claim fails |
| Whether plaintiff’s hearsay evidence (counsel’s statements via Aguilar) could defeat summary judgment | Saldana informed DOC staff of misclassification; his communications would show defendants’ awareness | Plaintiff produced only Aguilar’s hearsay affidavit about Saldana’s calls; no direct affidavit from Saldana and DOC records show only procedural/date inquiries | Hearsay affidavit excluded at summary judgment; even assuming Saldana’s affidavit, no evidence that Region 2 decisionmakers knew of misclassification, so summary judgment still proper |
Key Cases Cited
- Burks v. Raemisch, 555 F.3d 592 (7th Cir.) (§ 1983 liability requires personal involvement; no vicarious liability)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (liability depends on a defendant’s own conduct and state of mind)
- Figgs v. Dawson, 829 F.3d 895 (7th Cir.) (summary judgment review standard)
- Armato v. Grounds, 766 F.3d 713 (7th Cir.) (Eighth Amendment requires deliberate indifference; negligence insufficient)
- Cairel v. Alderden, 821 F.3d 823 (7th Cir.) (evidence at summary judgment must be admissible at trial)
- Wragg v. Village of Thornton, 604 F.3d 464 (7th Cir.) (form requirements for admissible evidence at summary judgment)
- Campbell v. Peters, 256 F.3d 695 (7th Cir.) (deliberate indifference standard in confinement contexts)
- Daniels v. Williams, 474 U.S. 327 (1986) (negligence by state official does not violate Due Process)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (negligently inflicted harm is below constitutional threshold)
- Davis v. Wessel, 792 F.3d 793 (7th Cir.) (reiterating negligence vs. constitutional standard)