Hutton v. Jeffreys
3:22-cv-02683
| S.D. Ill. | Jul 26, 2023Background:
- Plaintiffs Cody Hutton, Aaron Hardwick, and Michael Gilford are civilly committed under the Illinois Sexually Dangerous Persons Act (SDPA) and are housed at Big Muddy River Correctional Center.
- Plaintiffs allege the Sexually Dangerous Persons Program (SDPP) is understaffed and underfunded (one clinician for ~152 patients), causing severely limited therapy (≈1 hr/week, frequent cancellations), no regular didactic curriculum, missed semi-annual evaluations, and stale individualized treatment plans.
- Plaintiffs contend these deficiencies prevent progress toward recovery and amount to punitive conditions comparable to convicted prisoners (lockups, limited out-of-cell time, poor healthcare, property restrictions).
- Defendants sued in official capacities: Rob Jeffreys (IDOC Director), Sara Brown-Foiles (SDP program coordinator), Heather DeLashmutt (SDPP clinical director).
- Claims enumerated in the Complaint: Count 1 (funding/staffing; Eighth/Fourteenth), Count 2 (due-process right to adequate treatment), Count 3 (individualized treatment plans), Count 4 (ADA/Rehabilitation Act), Count 5 (biased recovery/release evaluations), Count 6 (constitutional challenge to 725 ILCS 205/9(d)).
- Court conducted preliminary screening under 28 U.S.C. § 1915A and allowed some Fourteenth Amendment claims to proceed while dismissing others without prejudice.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of SDPP staffing/funding and conditions (Counts 1–3) | Understaffing/cancellations and lack of treatment violate Fourteenth Amendment due-process rights of civil detainees and amount to punitive conditions | Program funding/staffing lawful; Eighth Amendment standard not applicable to civil detainees | Fourteenth Amendment claims for inadequate treatment and lack of individualized plans proceed against all defendants; Eighth Amendment portion dismissed |
| ADA and Rehabilitation Act (Count 4) | Plaintiffs, as civilly detained mental-health patients, are disabled and were excluded from programs/treatment because of disability | SDP designation is a sexual behavior disorder excluded from ADA; plaintiffs did not allege an otherwise qualifying disability or federally funded program element for RA | Dismissed without prejudice for failure to allege a qualifying disability under the ADA/RA |
| Recovery/release evaluations (Count 5) | Wexford-contracted evaluators perform evaluations that do not follow accepted professional standards, prejudicing release determinations | Evaluations are proper and contractual; no sufficient showing of bias (implicit defense) | Claim allowed to proceed against all defendants for further development |
| Challenge to 725 ILCS 205/9(d) two-year filing bar (Count 6) | Section 9(d) imposes a de facto two-year sentence and infringes Fourteenth Amendment liberty because it bars filings regardless of psychological condition | Statute contains an exception for "exceptional progress" by the treatment provider, so it does not impose an absolute two-year sentence | Dismissed without prejudice because the statute includes a pathway to overcome the two-year bar |
Key Cases Cited
- Smego v. Mitchell, 723 F.3d 752 (7th Cir. 2013) (civilly committed SDPA detainees treated as pretrial detainees for constitutional analysis)
- Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019) (Fourteenth Amendment objective-reasonableness standard governs medical claims by detainees)
- McCann v. Ogle Cty., Illinois, 909 F.3d 881 (7th Cir. 2018) (due-process framework for treatment of civil detainees)
- Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018) (standards for medical/detention conditions claims by pretrial detainees)
- Jackson v. City of Chicago, 414 F.3d 806 (7th Cir. 2005) (elements of ADA and Rehabilitation Act prima facie case)
- Pennsylvania Dep’t of Corrections v. Yeskey, 524 U.S. 206 (1998) (ADA applies to state prisons)
- Howe v. Godinez, 558 F. Supp. 3d 664 (S.D. Ill. 2021) (recognizing § 1983 claims for failure to treat persons civilly committed under SDPA)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)