Mosby v. Logan Correctional Center
3:24-cv-03199
C.D. Ill.May 2, 2025Background
- Shameka Mosby, plaintiff and a pro se litigant, filed an Amended Complaint under 42 U.S.C. § 1983 regarding conditions at Logan Correctional Center in May and June 2024.
- She alleges being left in a dark cell after the lights went out, exposure to a stopped-up toilet and feces, and unsafe shower conditions including mold and falling rusted/broken fixtures.
- Mosby and other inmates repeatedly complained to correctional staff but were only informed that work orders had been placed.
- The only named defendant in the Amended Complaint is Logan Correctional Center itself, a physical facility rather than an individual person.
- The court screened the complaint under 28 U.S.C. § 1915A, which requires dismissal of claims that are legally insufficient or seek relief from immune entities.
- The court granted Mosby leave to amend her complaint to identify actual persons subject to suit under § 1983 and set a 21-day deadline for amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Logan Correctional Center can be sued under § 1983 | Mosby sues the Correctional Center for violations of her rights based on conditions of confinement. | (Not required; decided on legal immunity at screening stage.) | A physical building is not a "person" subject to suit under § 1983. Case dismissed without prejudice. |
| Sufficiency of conditions of confinement claim under the Eighth Amendment | Mosby describes unsafe, unsanitary, and inhumane living conditions. | (Not required; merits not addressed due to procedural defect.) | Plaintiff may have a claim but must identify a proper defendant who knew of and disregarded the conditions. |
| Requirement to identify proper defendants for § 1983 suit | Complaint only names Logan Correctional Center. | (Not required; decided at screening.) | Mosby must name individual persons (by name or John/Jane Doe) as defendants for case to proceed. |
| Leave to file second amended complaint | Mosby seeks to amend; motion granted. | (No argument.) | Granted 21 days to file a proper amended complaint or the case will be dismissed. |
Key Cases Cited
- Smith v. Knox County Jail, 666 F.3d 1037 (7th Cir. 2012) (correctional facility is not a "person" suable under § 1983)
- Snyder v. King, 745 F.3d 242 (7th Cir. 2014) (Section 1983 only permits suits against persons, not buildings or institutions)
- Alexander v. United States, 721 F.3d 418 (7th Cir. 2013) (pleadings must state a plausible claim for relief)
- Turley v. Rednour, 729 F.3d 645 (7th Cir. 2013) (allegations are construed liberally in favor of pro se plaintiffs)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (officials liable under Eighth Amendment if they know of and disregard excessive risk to inmate safety)