Williams v. Commissary Department of the Department of Corrections
948 N.E.2d 1061
Ill. App. Ct.2011Background
- In May 1994, Williams was convicted of two counts of aggravated battery on a correctional officer and sentenced to consecutive 10-year terms.
- In February 1996, this court affirmed Williams' conviction and sentences (People v. Williams, 277 Ill.App.3d 1053).
- In July 2009, Williams, pro se, filed a 42 U.S.C. § 1983 complaint alleging prison-spending limits and restricted media access.
- In January 2010, the trial court dismissed the complaint as frivolous with no arguable basis in law or fact.
- Williams appeals the dismissal; the appellate court affirms and sanctions Williams for frivolous litigation, directing potential Rule 375(b) sanctions and disallowing new filings pending response.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint is time-barred | Williams argues timely §1983 claims were stated. | Defendants contend untimeliness as to the claims. | Claims are time-barred. |
| Whether administrative exhaustion was satisfied | Williams contends exhaustion requirements were met. | Defendants argue exhaustion was not shown. | Exhaustion not satisfied. |
| Whether the claims are substantively meritorious | Williams asserts rights violations by commissary limits and media access. | Defendants argue the claims are meritless. | Claims meritless; affirmed dismissal. |
Key Cases Cited
- People v. Williams, 277 Ill.App.3d 1053 (1996) (affirmation of conviction and sentences on direct appeal)