Paul Chatman v. Illinois Department of Correct
685 F. App'x 487
| 7th Cir. | 2017Background
- Plaintiff Paul Chatman, an Illinois prisoner, sued under 42 U.S.C. § 1983 after a planned tactical “Orange Crush” shakedown of his cellblock on April 30, 2014.
- Chatman alleges a degrading strip search in view of other inmates and female guards, forced manipulation of genitals, and being made to hold his mouth open without opportunity to wash hands.
- After the search he was partially clothed, marched through a line of guards who shoved and taunted him, then handcuffed to an outdoor metal gate in 30°F weather for ~90 minutes without coats; wind-driven water from a hydrant worsened the conditions and aggravated his asthma.
- Chatman alleges guards urinated in his cell; he was denied cleaning supplies. He filed grievances and then this suit shortly before the statute of limitations ran.
- The district court dismissed the complaint at screening under 28 U.S.C. § 1915A for failure to state an Eighth Amendment claim; the Seventh Circuit vacated and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chatman stated an Eighth Amendment claim based on strip search and public humiliation | The strip search was degrading, conducted in view of others and female guards, and intended to humiliate | Complaint lacks detail to show an unconstitutional, nonpenological purpose or excessive humiliation | Court: Allegations are sufficient at screening to plausibly infer gratuitous, degrading conduct; claim survives |
| Whether exposure to cold and shackling states an Eighth Amendment claim | Being handcuffed outdoors in freezing, windy weather without adequate clothing (and doused with water) was punitive and caused pain/breathing difficulty | Defendants may assert a penological justification; district court found no plausible lack of legitimate reason | Court: Short exposure need not cause lasting harm; scheduled shakedown undercuts any legitimate emergency—allegations suffice |
| Whether dismissal for lack of detail was appropriate under Rule 8 and § 1915A | Chatman contends Rule 8 requires only short, plain statement; more detail not required at screening | District court required more specifics about search manner and duration of deprivations | Court: Rule 8 satisfied; if complaint were truly sparse, plaintiff must be allowed to amend before dismissal, which did not occur |
| Whether supervisory defendants may be liable for failing to stop subordinates | Chatman alleges warden/lieutenants knew of and did not stop the conduct | Defendants argued lack of plausible supervisory culpability at screening | Court: Complaint alleges a course of conduct and knowledge; claims should proceed to allow defendants to answer and, if offered, justify actions |
Key Cases Cited
- King v. McCarty, 781 F.3d 889 (7th Cir.) (Eighth Amendment liability for conduct motivated to harass or humiliate)
- Mays v. Springborn, 575 F.3d 643 (7th Cir.) (standards for humiliating searches and how penological justifications shift burdens)
- Calhoun v. DeTella, 319 F.3d 936 (7th Cir.) (vacating dismissal where male prisoner was strip-searched in view of female guards)
- Dixon v. Godinez, 114 F.3d 640 (7th Cir.) (exposure to cold can violate Eighth Amendment even without lasting injury)
- Del Raine v. Williford, 32 F.3d 1024 (7th Cir.) (short exposure to bitter cold may be unconstitutional)
- Perez v. Fenoglio, 792 F.3d 768 (7th Cir.) (pro se plaintiffs should be allowed to amend deficient complaints before dismissal)