Jordan v. Wagner, 3:17-cv-00209

Background

Plaintiff Pierre Jordan, a state prisoner, sued under 42 U.S.C. § 1983 for events at Pinckneyville Correctional Center in 2014–2015, alleging denial of mental-health care, excessive force, denial of meals, property loss, failure to provide medical care after an assault, a false disciplinary report, and retaliation.
On July 21, 2014 Jordan told officers he was suicidal; he then attempted suicide and alleges officers (Wagner, Coffey, Flowers) failed to summon mental-health help and subsequently used excessive force, threatened him, tightened cuffs, dragged him, and left him restrained.
On July 28, 2014 Jordan was assaulted by a cellmate after reporting safety concerns; he claims Wagner and Chapman later refused to obtain needed medical care for his injuries.
Jordan also alleges Wagner stole his shoes and lost labeled property; C/O Cacioppo wrote a false disciplinary report (March 2015) that resulted in punishment; other claims involved retaliation and denial of transfer/disciplinary process problems.
The court screened the complaint under 28 U.S.C. § 1915A: it allowed deliberate-indifference-to-mental-health (Count 1), excessive-force (Count 3), and deliberate-indifference-to-medical-needs (Count 5) to proceed against Wagner, Coffey, Chapman, and Flowers; it dismissed Count 2 (missed meals) and Count 4 (property loss) with prejudice; Count 6 (failure to protect) was dismissed without prejudice for lack of identified defendants.
Counts 7 and 8 (due-process challenge to disciplinary proceedings and failure-to-transfer/investigate safety threats) were severed into a new case; several named parties without specific allegations were dismissed without prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate indifference to serious mental-health needs (Count 1)	Jordan says he told officers he was suicidal and they did nothing before his suicide attempt.	Officers would argue they did not act with deliberate indifference or that their actions were reasonable under the circumstances.	Court allowed Count 1 to proceed (pleaded enough to state a § 1983 deliberate-indifference claim).
Excessive force after suicide attempt (Count 3)	Jordan alleges officers slammed him, banged his head, wrapped cord around his neck, threatened him and used unnecessary force while he was not resisting.	Defendants would assert force was necessary to restrain/manage the situation or for safety/discipline.	Court allowed Count 3 to proceed (allegations plausibly show malicious/sadistic force).
Deliberate indifference to medical needs after cellmate assault (Count 5)	Jordan claims visible injuries and that Wagner and Chapman refused to summon further medical care.	Defendants would claim initial medical attention was provided and no deliberate indifference occurred.	Court allowed Count 5 to proceed (sufficient allegation that officers were aware and failed to act).
Other claims, joinder, and procedural defects (Counts 2,4,6,7,8; unnamed/uncharged defendants)	Jordan alleged missed meals, property loss, failure-to-protect, false disciplinary report, retaliation, and other concerns across many officials.	Defendants/Rule 20 concerns: unrelated claims/defendants, lack of facts tying some defendants to claims, adequate state remedies for property loss.	Court dismissed Count 2 (missed meals) and Count 4 (property loss) with prejudice; Count 6 (failure to protect) dismissed without prejudice for lack of identified defendants; Counts 7 and 8 severed into a new action; several named but un-pled defendants dismissed without prejudice.

Key Cases Cited

Neitzke v. Williams, 490 U.S. 319 (frivolousness standard for § 1915) (explaining when a claim is legally frivolous)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard) (plausibility required to survive dismissal)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard) (courts need not accept conclusory legal statements)
Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment) (prison officials’ duty to protect and deliberate-indifference standard)
Wilkins v. Gaddy, 559 U.S. 34 (excessive force) (malicious and sadistic vs. good-faith discipline standard)
Hudson v. Palmer, 468 U.S. 517 (due process/property) (state post-deprivation remedies can preclude § 1983 property claims)
Sanville v. McCaughtry, 266 F.3d 724 (7th Cir.) (mental-health need may be a serious medical need)
George v. Smith, 507 F.3d 605 (7th Cir.) (unrelated claims against different defendants should be in separate suits)