Ronald Ruhl v. Marcus Hardy
692 F. App'x 295
| 7th Cir. | 2017Background
- Ronald Ruhl discovered via an Illinois Auditor General report that the Illinois Department of Corrections (IDOC) had been adding a 7% “overhead” charge above the statutory 25% markup cap for commissary items, resulting in >$10.8 million in overcharges over five years.
- IDOC stopped the practice in 2012 but refused to refund past overpayments.
- Ruhl sued in Illinois state court seeking refunds and asserted a due process claim; he lost in state court and the Illinois Supreme Court denied review.
- Ruhl then filed a § 1983 action in federal court alleging denial of property without due process.
- The district court dismissed under § 1915A, relying primarily on Tenny v. Blagojevich, which treated similar claims as foreclosed.
- The Seventh Circuit affirmed dismissal, principally on claim-preclusion grounds because Ruhl fully litigated the refund/due-process issues in state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether IDOC’s refusal to refund overcharges violated procedural due process | Ruhl: statutory 25% cap created a protected property interest; refusing refunds deprived him of property without due process | IDOC: prior state-court rulings and available state remedies foreclose a federal due-process claim; state courts rejected a protected property interest | The Seventh Circuit affirmed dismissal: claim preclusion bars relitigation because Ruhl fully litigated the same claim in state court |
| Whether Illinois law created a constitutionally protected property interest in commissary price caps | Ruhl: § 3-7-2a creates an enforceable property interest in price cap | IDOC: Illinois courts have held no constitutional property right in commissary prices; no protected interest exists | Court noted Illinois appellate decisions rejecting a protected interest, undermining any due-process claim |
| Whether Illinois provides an adequate postdeprivation remedy such that due process is not implicated | Ruhl: postdeprivation tort remedy may be inadequate to remedy constitutional deprivation | IDOC: Tenny held state tort remedy sufficed; thus no procedural due process violation | Court did not resolve Tenny’s continuing force; relied on claim preclusion instead |
| Whether federal court can relitigate issues decided (or could have been decided) in state court | Ruhl: sought federal § 1983 relief after losing in state court | IDOC: Ruhl’s state-court final judgment precludes relitigation in federal court | Held: Claim preclusion applies; plaintiff must pursue certiorari, not a new federal suit |
Key Cases Cited
- Tenny v. Blagojevich, 659 F.3d 578 (7th Cir. 2011) (rejected inmates’ due-process claims over commissary markups, relying on adequacy of state postdeprivation remedy)
- Frey Corp. v. City of Peoria, Ill., 735 F.3d 505 (7th Cir. 2013) (discusses prerequisites for constitutional property interests)
- Leavell v. Ill. Dep’t of Nat. Res., 600 F.3d 798 (7th Cir. 2010) (addresses when state law creates a protected property interest)
- Hayes v. City of Chi., 670 F.3d 810 (7th Cir. 2012) (federal courts give state-court judgments the same preclusive effect they have in the rendering state)
- Jackson v. Randle, 957 N.E.2d 572 (Ill. App. Ct. 2011) (held prisoners have no constitutional right to commissary items at a specified price)
- Ruhl v. Dep’t of Corrs., 35 N.E.3d 982 (Ill. App. Ct. 2015) (applied Jackson to reject Ruhl’s due-process claim in state court)
- Ruhl v. Ill. Dep’t of Corrs., 42 N.E.3d 375 (Ill. 2015) (Illinois Supreme Court denied review of the state appellate judgment)