Smith v. Dart
803 F.3d 304
| 7th Cir. | 2015Background
- Donald A. Smith, a pretrial detainee and Army veteran, sued Cook County Sheriff Thomas J. Dart under 42 U.S.C. § 1983 alleging: sub-minimum pay ($3/day) for laundry work, inhumane work conditions (hot, smelly room), and multiple conditions-of-confinement deprivations (insufficient/nutritionally deficient food, rodents/insects, no mirrors, lack of outdoor recreation, and contaminated/filthy water).
- The district court conducted § 1915A screening: it dismissed wage/work claims (ruling detainees have no constitutional right to minimum wage) and allowed conditions claims to proceed initially.
- Dart moved to dismiss under Rule 12(b)(6) (or for a more definite statement). Smith filed two pro se letters adding factual allegations; the district court treated them inconsistently, granted the motion as uncontested, dismissed without prejudice, and directed Smith to file an amended complaint.
- Smith filed two post-dismissal motions construed as motions for reconsideration; the district court denied them and ultimately dismissed the case with prejudice under Rule 41(b) for failure to amend.
- On appeal, the Seventh Circuit reviewed de novo. It held that some of Smith’s post-filing factual letters should have been considered with respect to the sufficiency of his complaint, and it reversed dismissal as to two specific conditions claims while affirming other rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether wage/work claims are governed by the FLSA or constitute unconstitutional servitude | Smith: paid $3/day and compelled to work in harsh conditions; entitled to FLSA protection and relief under Thirteenth/Fourteenth Amendments | Dart: detainees/prisoners are not FLSA employees; participation in voluntary jail program is not involuntary servitude; loss of program privileges is not constitutional punishment | Held: Affirmed dismissal. Pretrial detainees are not covered by the FLSA; Smith’s participation was voluntary so no Thirteenth Amendment/involuntary servitude violation. |
| Whether alleged inadequate food states a conditions-of-confinement claim | Smith: meals are nutritionally deficient; first letter expressly alleges food is “well below nutritional value” | Dart: original complaint lacked sufficient factual detail to show constitutional deprivation | Held: Reversed dismissal as to inadequate food — allegation of nutritionally deficient diet is sufficient at pleading stage. |
| Whether pest infestations (rodents/insects) state a conditions-of-confinement claim | Smith: alleged numerous pests on tiers, nests, pests in showers/toilets, etc. | Dart: allegations are conclusory; degree and effect of infestation not pleaded | Held: Affirmed dismissal as to pest claim — mere list of pests without facts about extent, personal contact, injury, or frequency is insufficient. |
| Whether contaminated water, lack of outdoor recreation, and other conditions state claims | Smith: alleged filthy water, contaminants (radiation, cyanide, lead), inability to go outside for recreation; later filings added water contamination specifics | Dart: insufficient factual allegations to show water unsafe or deprivation of exercise | Held: Reversed dismissal as to contaminated water — allegations of specific contaminants were enough at pleading stage; affirmed dismissal as to lack of outdoor recreation (no allegation that movement/exercise was denied to dangerous/atrophy-producing extent). |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainees may not be subjected to conditions that constitute punishment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment requires prison officials to provide basic human needs)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim)
- Antonelli v. Sheahan, 81 F.3d 1422 (7th Cir. 1996) (pest infestations may support a conditions claim when facts show pervasive contact/harm)
- French v. Owens, 777 F.2d 1250 (7th Cir. 1985) (prisoners entitled to nutritionally adequate food)
- Bennett v. Frank, 395 F.3d 409 (7th Cir. 2005) (prisoners are not FLSA employees)
- Sanders v. Hayden, 544 F.3d 812 (7th Cir. 2008) (civil detainees are not covered by the FLSA)