Deion Turner v. Salvador Godinez, 693 F. App'x 449

Background

Turner, a previously convicted sex-offender, was arrested in 2010 and detained 212 days pretrial; arrested again in 2011 and detained 699 days pretrial. The sentencing court’s orders of commitment reflected 212 and 699 days’ credit (total 911 days).
IDOC staff at Stateville and Dixon calculated Turner’s release date using only 699 days’ credit, and Turner remained incarcerated until April 1, 2014, serving 1,119 days before being released to supervised release.
Turner filed state-court petitions and two federal § 1983 suits alleging he was held beyond his mandatory release date in violation of the Eighth Amendment; the first federal suit was dismissed as premature and summary-affirmed; the second was dismissed by the district court on multiple grounds.
Defendants argued the case was barred by Rooker–Feldman, issue preclusion, and various immunities; the district court accepted those arguments and dismissed the suit in full.
The Seventh Circuit held that Rooker–Feldman and issue preclusion do not bar Turner’s deliberate-indifference Eighth Amendment claim and that Turner stated plausible claims against two defendants (the Stateville Institutional Record Office supervisor and Becky Williams at Dixon) but not against other defendants.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker–Feldman bars Turner's § 1983 challenge to being held past his mandatory release date	Turner: injury caused by prison officials’ failure to apply ordered credits, not by a state-court judgment	Defendants: federal review would overturn state-court determinations; Rooker–Feldman applies	Not barred: Rooker–Feldman irrelevant because no state-court judgment adverse to Turner and state appeals were pending when federal suits were filed
Whether issue preclusion prevents relitigation of the jurisdictional/merits questions	Turner: no state-court merits decision on release-date calculation	Defendants: prior federal dismissal or state decisions preclude suit	Not precluded: prior federal dismissal was procedural (prematurity) and did not decide merits; state rulings did not determine that prison credits were correct
Whether Turner plausibly alleged an Eighth Amendment deliberate-indifference claim	Turner: supervisors knew of incorrect credits (grievances, orders of commitment) and ignored risk of continued incarceration	Defendants: errors were clerical/neglect; staff reasonably deferred to records or experts; some defendants lacked personal involvement	Plausible claim as to Stateville record supervisor and Becky Williams at Dixon; allegations show knowledge and failure to act to apply credits
Whether other defendants are liable or immune	Turner: many officials involved in processing grievances and representation	Defendants: grievance staff reasonably relied on specialists; prosecutors and public defenders immune or not state actors; others lacked personal involvement	Affirmed dismissal as to all other defendants: grievance staff not deliberately indifferent, prosecutors immune, public defenders not acting under color of state law, and absence of personal involvement for remaining defendants

Key Cases Cited

Exxon Mobil Corp. v. Saudi Basic Indus., 544 U.S. 280 (doctrine prevents federal review of state-court judgments)
Jakupovic v. Curran, 850 F.3d 898 (7th Cir.) (Rooker–Feldman scope discussion)
Figgs v. Dawson, 829 F.3d 895 (7th Cir.) (record supervisor liability where minimal investigation of release-date error)
Werner v. Wall, 836 F.3d 751 (7th Cir.) (Eighth Amendment deliberate-indifference framework for detention-credit disputes)
Burke v. Johnston, 452 F.3d 665 (7th Cir.) (permitting claim where DOC officials delayed granting credit)
Campbell v. Peters, 256 F.3d 695 (7th Cir.) (Eighth Amendment deliberate-indifference standard in prison contexts)
Imbler v. Pachtman, 424 U.S. 409 (prosecutorial immunity)
Polk County v. Dodson, 454 U.S. 312 (public defenders not acting under color of state law for § 1983)