James v. St Joseph Co Jail et al
OPINION AND ORDER: This case is DISMISSED under 28 U.S.C. § 1915A. Signed by Judge Damon R Leichty on 05/10/2022. (Copy mailed to pro se party) (jdb)
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
SOUTH BEND DIVISION
SILAS L. JAMES,
CAUSE NO. 3:22-CV-367-DRL-MGG
ST. JOSEPH CO. JAIL et al.,
OPINION AND ORDER
Silas L. James, a prisoner without a lawyer, filed a complaint against the St. Joseph
County Jail, Sgt. Heath, and Sgt. Moreno. ECF 1. “A document filed pro se is to be liberally
construed, and a pro se complaint, however inartfully pleaded, must be held to less
stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551
U.S. 89, 94 (2007) (quotation marks and citations omitted). Under 28 U.S.C. § 1915A, the
court still must review the merits of a prisoner complaint and dismiss it if the action is
frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks
monetary relief against a defendant who is immune from such relief.
Mr. James alleges that, on January 8, 2022, he had a towel on his head because he
had symptoms consistent with Covid-19. Having a towel on his head at this time violated
the jail’s rules. Mr. James was told that, if he refused to remove the towel from his head,
it would be treated as a refusal of his breakfast tray. He refused to remove the towel, and
he was not provided with breakfast. He believes this is a violation of his rights.
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Because Mr. James is a pretrial detainee, his claim must be assessed under the
Fourteenth Amendment, which prohibits holding pretrial detainees in conditions that
“amount to punishment.” Mulvania v. Sheriff of Rock Island Cnty., 850 F.3d 849, 856 (7th
Cir. 2017) (quoting Bell v. Wolfish, 441 U.S. 520, 535 (1979)). The Fourteenth Amendment
guarantees inmates “the minimal civilized measure of life’s necessities,” including
adequate nutrition. See Hardeman v. Curran, 933 F.3d 816, 820 (7th Cir. 2019) (citations
omitted); Smith v. Dart, 803 F.3d 304, 310 (7th Cir. 2015). If a pretrial condition falls below
this level, a plaintiff must show the condition was the result of a defendant’s purposeful,
knowing, or perhaps reckless conduct and that the defendant’s conduct was objectively
unreasonable. Miranda v. Cnty. of Lake, 900 F.3d 335, 353-54 (7th Cir. 2018) (citing Kingsley
v. Hendrickson, 135 S. Ct. 2466, 2472-74 (2015)). A defendant’s conduct is objectively
unreasonable if the challenged condition “is ‘imposed for the purpose of punishment,’ or
. . . if the condition ‘is not reasonably related to a legitimate goal—if it is arbitrary or
purposeless[.]’” Mulvania, 850 F.3d at 856 (quoting Bell, 441 U.S. at 538-39).
Missing a single meal did not deny Mr. James the minimal civilized measure of
life’s necessities. “There is, of course, a de minimus level of imposition with which the
Constitution is not concerned.” Ingraham v. Wright, 430 U.S. 651, 674 (1977). There are
many reasons why people, inmates and free citizens alike, will occasionally miss a meal.
Furthermore, Mr. James could have had breakfast if he had only removed the towel from
his head as required. He did not comply with a condition for receiving breakfast and so
he was not given breakfast. He has only himself to blame for his missed meal. See, e.g.,
Freeman v. Berge, 441 F.3d 543, 545 (7th Cir. 2006) (inmate who was denied food because
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he refused to comply with a prison rule requiring him to wear pants was “the author of
his deprivation rather than a victim of punishment”).
Mr. James also complains that not providing him with breakfast violated the jail’s
rules. The Constitution does not protect Mr. James from violations of the jail’s policy. See
Scott v. Edinburg, 346 F.3d 752, 760 (7th Cir. 2003) (“However, 42 U.S.C. § 1983 protects
plaintiffs from constitutional violations, not violations of state laws or, in this case,
departmental regulations and police practices.”). Thus, Mr. James’s complaint does not
state a claim.
“The usual standard in civil cases is to allow defective pleadings to be corrected,
especially in early stages, at least where amendment would not be futile.” Abu-Shawish v.
United States, 898 F.3d 726, 738 (7th Cir. 2018). However, “courts have broad discretion to
deny leave to amend where . . . the amendment would be futile.” Hukic v. Aurora Loan
Servs., 588 F.3d 420, 432 (7th Cir. 2009). For the reasons previously explained, such is the
For these reasons, this case is DISMISSED under 28 U.S.C. § 1915A.
May 10, 2022
s/ Damon R. Leichty
Judge, United States District Court
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