David Armato v. Randy Grounds
2014 U.S. App. LEXIS 17265
7th Cir.2014Background
- Armato, a convicted sex offender, faced two separate theft convictions in Illinois and was sentenced to ten years for the second offense, with concurrent terms and no mandatory supervised release (MSR) term specified.
- IDOC initially projected Armato’s release date to May 9, 2010, due to good time credit, but later recalculations created tension about MSR terms and release timing.
- Littlejohn, the records supervisor at Robinson, noticed inconsistent time credits (claiming Armato could not have been in Lake County Jail since December 2005) and recalculated a later release date, suggesting MSR concerns.
- Two typed judgment orders (Feb 18, 2010) and a handwritten Agreed Order set Armato’s potential release; the Agreed Order stated release on May 28, 2010 without MSR; typed orders did not specify a release date.
- IDOC officials believed MSR was mandatory and sought AG’s Office intervention; when unresolved, Armato was subjected to “violations at the door” in February–April 2010 while awaiting AG decision.
- Armato filed a §1983 and state-law false imprisonment suit in 2011; the district court granted summary judgment on multiple grounds, which the Seventh Circuit affirmed, concluding no injury and no constitutional violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Armato was unlawfully detained beyond release date | Armato | IDOC followed orders | No, compliant with the Agreed Order and typed orders; no injury. |
| Effect of handwritten Agreed Order vs typed orders on release date | Armato relied on the handwritten order | Agreed Order controls; typed orders not dispositive | Agreed Order control; no detention beyond May 28, 2010. |
| Eighth Amendment claim—deliberate indifference | Defendants knowingly held him beyond lawful release | Reasonable interpretation of state law; not deliberate indifference | Failing claims; not deliberate indifference given efforts to obtain legal clarification. |
| Procedural due process and available state remedies | He lacked proper process and remedies | State remedies (habeas, mandamus, false imprisonment) adequate | Precluded by adequate state-law remedies; no due process violation. |
Key Cases Cited
- Parratt v. Taylor, 451 U.S. 527 (1981) (elements of §1983 liability and due process principles)
- Campbell v. Peters, 256 F.3d 695 (7th Cir. 2001) (state officials may rely on reasonable statutory interpretations)
- DeGuelle v. Camilli, 724 F.3d 933 (7th Cir. 2013) (state judgments given same effect as state courts would)
- Toney-El v. Franzen, 777 F.2d 1224 (7th Cir. 1985) (state-court remedies adequate to preclude due process claims)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment standard and absence of genuine issues)
- First Nat. Bank of Ariz. v. Cities Service Co., 391 U.S. 253 (1968) (standard for determining genuine issues of material fact)