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Chapman v. Decker
, No. 23-cv-3200-JPG (Southern District of Ill. (S.D. ILL))
Case details
Full caption
CHAPMAN v. OFFICER DECKER
Country
United States
Jurisdiction
Federal
Court
Southern District of Illinois (S.D. ILL)
Disposition
Motion Denied
UNITED
STATES
DISTRICT
COURT
FOR
THE
SOUTHERN
DISTRICT
OF
ILLINOIS
JOHN
P.
CHAPMAN,
Plaintiff,
v.
OFFICER
DECKER,
SERGEANT
RIC
H
ERT,
SGT.
HARING,
SGT.
CALDWELL,
LT.
S
ELLERS,
OFFICER
DA
WDY,
and
LT.
FOSTER,
Defendant.
Case
No.
23-cv-3200-JPG
MEMORANDUM
AND
ORDER
This
matter
comes
before
the
Court
on
th
e
defendants’
motion
for
summary
judgment
(Doc.
54).
Plaintiff
John
P.
Chapman
ha
s
responded
to
the
motion
(Doc.
58),
and
the
defendants
1
have
replied
to
that
response
(Doc.
62
).
The
Court
also
considers
the
defendants’
motion
to
deem
admitted
the
facts
in
their
statement
of
material
facts
within
their
motion
pursuant
to
SDIL-LR
56.1(g)
(Doc.
60).
Chapman
has
not
responded
to
that
motion.
I.
Background
Chapman
filed
this
case
pro
se
complaining
that,
with
the
exception
of
defendant
Sgt.
Caldwell,
2
the
defendants
used
excessive
force
by
beating
him
on
February
9,
2022,
and
on
March
3,
2022,
they
failed
to
intervene
in
the
use
of
excessive
force,
or
they
failed
to
provide
adequate
medical
care
after
the
February
9,
2022,
exces
sive
force.
The
defendants
contend
that
any
force
they
used
on
February
9,
2022,
was
objec
tively
reasonable
and
was
executed
without
a
reasonable
opportunity
to
intervene,
that
summon
ing
medical
care
that
did
not
arrive
until
the
1
In
this
order,
the
Court
refers
to
each
defendant
by
the
name
they
use
in
their
motion,
not
the
names
Chapman
uses
in
his
pleading.
2
The
Court
dismissed
Caldwell
without
prejudice
in
its
screening
order
(Doc.
10).
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following
day
was
reasonable,
and
that
there
was
no
force
used
on
March
3,
2022.
They
also
argue
that
they
are
entitled
to
qualified
immunity
and
that,
in
any
case,
any
injury
Chapman
suffered
was
not
caused
by
their
conduct.
The
Court
will
grant
in
part
and
deny
in
part
the
defendants’
motion
for
summary
judgment
because
there
are
genuin
e
issues
of
material
fact
about
whether
the
defendants
used
excessive
force
against
Chapman,
but
not
whether
a
defendant
unreasonably
failed
to
intervene
when
they
had
a
chance
or
unreasonably
failed
to
summon
medical
care
for
Chapman.
II.
Summary
Judgment
Standard
Summary
judgment
is
appropriate
on
ly
if
the
moving
party
can
show
“there
is
no
genuine
dispute
as
to
any
material
fact
and
the
movant
is
entitled
to
judgment
as
a
matter
of
law.”
Fed.
R.
Civ.
P.
56(a);
Celotex
Corp.
v.
Catrett
,
477
U.S.
317,
322
(1986).
A
genuine
dispute
of
material
fact
exists
when
“the
evidence
is
such
that
a
reasonable
jury
coul
d
return
a
verdict
for
the
nonmoving
party.”
Anderson
v.
Liberty
Lobby,
Inc.
,
477
U.S.
242,
248
(1986).
The
moving
party
has
the
burden
of
establishing
that
no
material
fact
is
genuinely
disputed.
Celotex
,
477
U.S.
at
323;
Modrowski
v.
Pigatto
,
712
F.3d
1166,
1168
(7th
Cir.
2013).
Once
a
properly
supported
motion
for
summa
ry
judgment
is
filed,
the
adverse
party
“must
set
forth
specific
facts
showing
that
there
is
a
genuine
issue
for
trial.”
Anderson
,
477
U.S.
at
250
(internal
quotations
omitted).
The
Court
does
not
decide
the
truth
of
the
matters
presented,
and
it
cannot
“choose
between
competing
inferences
or
balance
the
relative
weight
of
conflicting
evidence.”
McCottrell
v.
White
,
933
F.3d
651,
657
(7th
Cir.
2019)
(internal
quotations
omitted).
On
the
contrary,
“[t]he
eviden
ce
of
the
non-movant
is
to
be
believed,
and
all
justifiable
inferences
are
to
be
drawn
in
his
favor.”
Anderson
,
477
U.S
.
at
255.
If
the
“evidence
is
such
that
a
reasonable
jury
could
return
a
verdict
for
the
nonmoving
party[,]”
then
a
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genuine
dispute
of
material
fact
exists.
Zaya
v.
Sood
,
836
F.3d
800,
804
(7th
Cir.
2016)
(internal
quotations
omitted).
Nevertheless,
the
Court
need
not
find
a
genui
ne
issue
of
material
fa
ct
where
the
story
of
one
side
is
blatantly
contradicted
by
the
record
such
that
no
reasonable
jury
could
believe
it.
Scott
v.
Harris
,
550
U.S.
372,
380
(2007)
(video
evidence).
Under
this
rule,
video
evidence
“can
resolve
a
genuine
dispute
at
summary
judgment[,
but
]
only
if
it
offers
‘irr
efutable
evidence’
that
‘utterly
discredit[s]’
countervailing
factual
assertions.”
Pam
v.
City
of
Evansville
,
154
F.4th
523,
529
(7th
Cir.
2025)
(citing
Gant
v.
Hartman
,
924
F.3d
445,
450
(7th
Cir.
2019));
Raddant
v.
Douglas
Cnty.,
Wisc.
,
170
F.4th
583,
591-92
(7th
Cir.
2026).
III.
Facts
A.
Defendants’
Statement
of
Material
Facts
As
a
preliminary
matter,
the
Court
considers
whet
her
to
deem
the
facts
in
the
defendants’
statement
of
material
facts
(“SOMF”)
admitted
b
ecause
Chapman
did
not
counter
them
in
his
motion
in
the
form
required
by
SDIL-LR
56.1.
That
rule
contempla
tes
that
the
summary
judgment
movants
include
in
their
brief
a
SOMF
“which
sets
forth
each
relevant,
material
fact
in
a
separately
numbered
paragraph”
with
“specific
citation(s)
to
the
record.”
SDIL-LR
56.1(a).
The
opposing
party’s
brief
must
then
contai
n
a
response
to
the
SOMF
with
corresponding
paragraphs
stating
whether
the
fact
is
admitted
or
disputed,
in
whole
or
in
part,
or
is
not
supported
by
the
record;
the
disputed
facts
must
contain
their
own
citation
to
the
record.
SDIL-
LR
56.1(b).
“All
material
facts
set
forth
in
a
[SOMF]
.
.
.
shall
be
deemed
admitted
for
purposes
of
summary
judgment
unless
specifically
disputed.”
SDIL-LR
56.1(g).
The
defendants
complied
with
SDIL-LR
56.1(a)
in
their
motion,
but
Chapman
did
not
include
in
his
brief
correspondi
ng
paragraphs
admitting,
disputi
ng,
or
challenging
the
supporting
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evidence
for
those
facts.
The
defendants
ask
th
e
Court
to
deem
the
facts
in
its
SOMF
admitted
in
light
of
SDIL-LR
56.1(g).
While
local
court
rules
are
designed
to
f
acilitate
orderly
litigation
and
to
achieve
the
ends
of
justice,
the
Court
has
discretion
to
overlook
a
transgression
of
those
rules,
Waldridge
v.
Am.
Hoechst
Corp.,
24
F.3d
918,
923
(7th
Cir.
1994),
and
the
inherent
authority
to
excuse
it.
Murata
Mfg.
Co.
v.
Bel
Fuse,
Inc.
,
242
F.R.D.
470,
474
(N.D.
Ill.
May
2,
2007).
Where
no
party
suffers
prejudice
from
a
failure
to
follow
the
local
rules
,
the
Court
may
exercise
flexibility
to
excuse
noncompliance.
The
defendants
have
suffered
no
prejudice
from
Chapman’s
failure
to
counter
the
facts
in
their
SOMF
in
corresponding
numbered
paragraphs
or
to
submit
his
own
statement
of
additional
material
facts.
Chapman’s
brief
contains
only
three
pages
of
factual
allegations,
supported
by
citations
to
the
record,
that
have
been
relatively
ea
sy
for
the
Court
to
sort
through
and
to
locate
factual
disputes.
The
Court
is
confident
that
the
defendants’
able
counsel
was
not
prejudicially
hampered
by
the
format
of
Chapman’s
presentation.
Accordingly,
the
Court
believes
it
is
appropriate
to
allow
this
departure
from
SDIL-L
R
56.1
in
the
interests
of
justice,
and
it
will
deny
the
defendants’
motion
to
deem
admitted
the
f
acts
in
its
SOMF.
Had
Chapman’s
statement
of
facts
been
longer
and
more
convoluted
or
not
w
ell
supported
by
citations
to
the
record,
the
Court
may
have
reached
a
different
conclusion.
B.
Relevant
Facts
The
admissible
evidence
and
the
reasonable
infe
rences
that
can
be
drawn
from
it,
viewed
in
Chapman’s
favor,
establish
the
following
relevant
facts.
Chapman
was
booked
into
the
Madison
County
J
ail
(“Jail”),
where
the
defendants
were
employed,
on
January
26,
2022.
At
the
time
he
arrived,
he
had
a
history
of
neurological
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problems
from
a
2016
gunshot
wound
to
the
head.
Those
problems
included
seizures
and
epilepsy
that
required
him
to
take
medications,
which
he
was
prescribed
and
offered
at
the
Jail,
although
he
refused
them
on
numerous
occasions.
His
seizures
and
need
for
medication
were
noted
on
his
booking
card.
Chapman
was
experiencing
seizures
in
January
2022
when
he
arrived
at
the
Jail
and
even
had
one
on
February
4,
2022,
in
a
c
ourt
hearing.
When
he
arrived
at
the
Jail,
he
was
also
experiencing
symptoms
of
withdrawal
from
methamphetamine.
The
events
that
gave
rise
to
this
case
be
gan
shortly
after
11:00
a.m.
on
February
9,
2022,
while
Chapman
was
a
pretrial
detainee.
Chapman
was
yelling
at
another
detainee
in
the
G-South
cellblock
to
give
him
his
tablet
computer
ba
ck.
Officer
Decker
heard
Chapman
propose
to
another
detainee
that
they
fight,
and
the
other
detainee
said
he
was
in
fear
for
his
life.
Decker
summoned
assistance,
stating
that
Chapman
had
been
fighting
and
was
refusing
to
return
to
his
cell.
Actually,
the
detainees
had
been
in
a
war
of
words
without
any
physical
contact.
Defendants
Lt.
Richert,
Lt.
Haring,
and
Sgt.
Dawdy
responded
to
Decker’s
call,
and
Chapman
returned
to
his
cell.
Decker
and
Richert
th
en
went
to
Chapman’s
cell
to
move
him
to
Segregation
Unit
1
for
fighting.
Chapman
initially
refused
multiple
orders
to
leave
his
cell
as
ordered,
but
eventually
did
after
Richert
took
hold
of
him
by
his
arm.
Decker
and
Richert
accompanied
him
to
the
hallway.
In
the
hallway,
Chapman
was
yelling
but
not
physically
resisting,
so
Decker,
Richert,
and
Haring
applied
physical
force
to
Chapman
for
se
veral
minutes
so
Dawdy
could
handcuff
him.
Specifically,
Chapman
was
ordered
to
get
down
on
his
hands
and
knees,
and
after
Chapman
was
on
one
knee,
Dawdy
placed
a
cuff
on
Chapman’s
right
hand.
Decker
then
punched
Chapman
on
the
right
side
of
his
head
three
times,
which
cau
sed
Chapman
to
fall
on
his
stomach.
Dawdy
was
then
able
to
place
the
other
cuff
on
Chapman’s
left
hand.
Chapman
expressed
disbelief
that
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Decker
had
hit
him
in
the
head
and
yelled
that
he
had
just
had
brain
surgery.
After
Chapman
was
fully
in
handcuffs
a
nd
lying
on
the
ground,
he
looked
up,
and
Richert
kicked
him
in
the
eye.
Chapman
was
not
resisting
during
the
incident,
and
no
officer
instructed
him
to
stop
yelling
or
resisting.
Dawdy
and
Decker
were
able
to
get
Chapman
to
his
feet
again
and
to
frog-march
him
down
the
hall
toward
Segregation
Unit
1.
Chapman
saw
Lt.
Foster
in
the
hallway
and
asked
why
the
officers
were
“doing
this,”
and
Foster
said
it
was
out
of
his
hands
and
he
was
sorry.
The
incident
in
the
hallway
is
recorded
on
video,
but
the
relevant
part
of
the
image
is
obscured
by
the
video
header,
the
video
is
missing
crucial
seconds,
and
it
is
essentially
unhelpful
except
to
show
that
Chapman
did
not
have
a
black
right
eye
as
he
walked
down
the
hall
after
being
handcuffed.
Later,
both
of
Chapman’s
eyes
became
black,
his
ear
was
bloody,
and
he
felt
pain.
Once
in
segregation,
Chapman
yelled
and
th
reatened
the
jail
officers
present—Decker,
Haring,
and
Dawdy.
He
knelt
down
as
instructed
but
refused
to
lie
down
so
the
handcuffs
could
be
removed
safely.
Haring
applied
force
to
Chap
man’s
legs
to
force
him
to
lie
down.
When
one
cuff
was
removed,
Chapman
did
not
comply
with
orde
rs
to
keep
his
free
arm
flat
on
the
floor
and
instead
used
it
to
try
to
push
up
from
his
prone
position.
Decker
applied
physical
force
to
the
back
of
Chapman’s
shoulder
to
try
to
keep
him
down.
When
Chapman
continued
to
resist,
Haring
sprayed
him
in
the
face
with
a
one-secon
d
blast
of
oleoresin
capsicum
(“OC”
or
pepper)
spray.
Chapman
then
allowed
the
officers
to
rem
ove
the
remaining
cuff
as
they
wanted
to.
Decker
told
Chapman
to
rinse
his
face
with
running
water
from
his
sink,
told
the
nursing
staff
about
the
incident,
and
asked
them
to
see
Chapm
an
as
soon
as
they
could
safely
do
so.
In
segregation,
Chapman
was
regularly
monitored.
He
verbally
threatened
jail
staff,
banged
on
his
cell
door,
and
spat
at
the
window
in
the
door.
By
about
5:30
p.m.,
Chapman
had
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calmed
down
enough
so
that
Foster
approve
his
r
emoval
from
segregati
on
and
placement
in
cellblock
C-North,
where
he
was
allowed
to
show
er.
As
a
result
of
the
events
of
February
9,
2022,
Chapman
was
placed
on
lockdown
for
30
days.
He
had
a
seizure
in
the
early
hours
of
February
10,
2022.
On
February
10,
2022,
Jail
medical
staff
evaluated
Chapman
and
noted
he
had
a
slightly
swollen
black
right
eye
that
he
said
was
from
fighting.
The
black
eye
did
not
result
from
a
fight
with
another
detainee
because
there
was
no
phys
ical
contact
during
that
fight.
Instead,
it
came
from
the
force
used
by
one
or
more
of
the
defendants.
Medical
staff
gave
Chapman
Tylenol
and
ice
packs
but
did
not
provide
any
other
care
or
treatment.
While
not
noted
in
his
medical
records,
Chapman
also
had
a
bloody
ear,
headaches
an
d
a
sudden
increase
in
seizure
activity
he
attributes
to
the
incident.
His
increased
seizure
s
continued
until
the
beginning
of
June,
when
he
received
medicine
from
a
neurologist.
On
February
14,
2022,
Chapman
was
sent
outside
the
jail
for
a
CT
scan
of
the
head
where
the
doctor
noted
no
acute
fracture
or
joint
dislocation
and
unremarkable
soft
tissues.
He
had
another
CT
scan
of
the
head
on
May
24,
2022,
after
which
the
doctor
found
no
acute
intracranial
process
and
postoperative
changes
of
the
left
frontal
craniotomy
and
mild
left
frontal
lobe
encephalo
malacia.
While
Chapman
offers
no
expert
proof
of
causation,
he
is
competent
to
testify
about
his
pain
and
the
increased
frequency
of
his
seizures
beginning
after
February
9,
2022.
On
March
3,
2022,
Chapman
had
a
migrain
e
headache
and
was
fed
up
with
another
inmate’s
making
loud
noises,
so
he
submitted
a
request
for
ment
al
health
care.
That
evening,
Officer
Sellers
took
Chapman
from
his
lockdown
cel
l
to
a
segregation
cell
and
then
kicked
him
three
times
on
the
right
side
of
his
body
and
one
or
two
times
on
the
left.
He
remained
on
the
floor
for
several
days
and
in
that
segregation
cell
on
suicide
watch
for
five
days.
Chapman
was
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in
pain
from
the
force
Sellers
used
on
him.
In
September
2023,
Chapman
filed
this
lawsu
it
under
42
U.S.C.
§
1983
alleging
violation
of
his
Fourteenth
Amendment
due
process
rights
based
on
the
defendants’
alleged
use
of
excessive
force,
failure
to
intervene,
and
de
liberate
indifference
to
his
medical
needs.
Specifically,
the
Court
identified
thes
e
claims
in
Chapman’s
Complaint:
Claim
1:
Eighth
or
Fourteenth
Amendment
3
excessive
force
claim
against
Decker,
Richert,
and
Sellers
for
allegedly
beating
Plaintiff
on
February
9,
2022,
and
March
3,
2022.
Claim
2:
Eighth
or
Fourteenth
Amendment
f
ailure
to
intervene
claim
against
Dawdy
and
Foster
for
failing
to
interve
ne
in
the
beating
by
Decker
or
Richert
on
February
9,
2022.
Claim
3:
Eighth
or
Fourteenth
Amendment
deliberate
indifference
claim
against
Haring
for
placing
Plaintif
f
in
a
cell
without
medica
l
care
after
the
beating
on
February
9,
2022.
(Doc.
10
at
3).
IV.
Analysis
A.
Count
1:
Excessive
Force
To
prove
a
defendant
used
excessive
force
in
violation
of
the
Fourteenth
Amendment,
a
pretrial
detainee
must
show
that
the
defendant
acted
purposefully,
knowingly,
or
perhaps
even
recklessly
in
response
to
conditions
posing
an
exce
ssive
risk
to
his
health
or
safety
and
that
the
defendant’s
actions
were
objectively
unreasonable.
Kingsley
v.
Hendrickson
,
576
U.S.
389,
395-
97
(2015).
Thus,
the
appropriate
standard
for
a
pre
trial
detainee’s
claim
is
not
whether
the
defendant
was
subjectively
aware
that
their
use
of
force
was
unreasonable.
Id.
at
396-97;
3
It
was
unclear
at
the
time
whether
Chapman
was
a
convicted
prisoner,
in
which
case
the
Eighth
Amendment
would
apply,
or
a
pretrial
detainee,
in
which
case
the
Fourteenth
Amendment
would
apply.
Miranda
v.
Cnty.
of
Lake
,
900
F.3d
335,
350-54
(7th
Cir.
2018)
(discussing
the
different
legal
standards
applied
to
claims
by
convicted
indi
viduals
versus
pretrial
detainees).
It
is
clear
now
that
he
was
a
pretrial
detainee.
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Raddant
v.
Douglas
Cnty.,
Wisc.
,
170
F.4th
583,
590
(7th
Cir.
2026).
As
with
other
uses
of
the
objective
standa
rd,
the
determination
turns
on
the
facts
and
circumstances
of
each
particular
case
from
th
e
perspective
of
a
reasonable
officer
in
the
defendant’s
position
and
what
they
knew
at
the
critical
time.
Kingsley
,
576
U.S.
at
397
(citing
Graham
v.
Connor
,
490
U.S.
386,
396
(1989));
Raddant
,
170
F.4th
at
590.
The
objective
circumstances
to
consider
incl
ude,
but
are
not
limited
to:
the
relationship
between
the
need
for
th
e
use
of
force
and
the
amount
of
force
used;
the
extent
of
the
plaintiff’s
injury;
any
effort
made
by
the
officer
to
temper
or
to
limit
the
amount
of
force;
the
severity
of
the
security
problem
at
issue;
the
threat
reasonably
perceived
by
the
officer
;
and
whether
the
plaintiff
was
actively
resisting.
Kingsley
,
576
U.S.
at
397
(citing
Graham
,
490
U.S.
at
396).
Of
course,
the
Court
may
consider
video
evidence
of
an
occurrence
in
its
evaluation
of
the
use
of
force.
The
Court
must
consider
in
its
determination
the
legitimate
interest
in
manag
ing
the
jail
and
must
defer
to
the
judgment
of
jail
officials
as
to
the
policies
and
practices
nece
ssary
to
maintain
institutional
security.
Kingsley
,
576
U.S.
at
397
(citing
Bell
v.
Wolfish
,
441
U.S.
520,
540
(1979)).
1.
February
9,
2022:
Hallway
Incident
Chapman
claims
that
Decker
and
Richert
used
excessive
force
agains
t
him
in
the
Jail
hallway
on
the
morning
of
February
9,
2022.
4
There
is
sufficient
evidence
for
a
reasonable
jury
to
find
they
used
excessive
force
in
that
incide
nt.
Specifically,
Chapman
testified
that
he
did
not
physically
resist,
although
he
admits
he
was
y
elling,
when
the
officers
began
to
put
him
in
handcuffs.
He
testified
that,
while
he
was
bei
ng
cooperative,
Decker
punched
him
three
times
in
the
head
and
that,
after
he
was
in
handcuffs
ly
ing
on
the
ground,
Richert
kicked
him
in
the
eye.
The
picture
he
paints
is
of
a
compliant
detainee
who
was
assaulted
gratuitously
with
purposeful
4
Chapman
does
not
complain
of
Se
llers’s
conduct
on
February
9,
2022.
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punches
and
kicks.
The
video
evidence
of
the
encounter
is
not
clear
enough
to
require
a
reasonable
jury
to
reject
Chapman’s
testimony.
The
details
are
hidden
behind
a
header
bar,
and
the
video
omits
several
seconds
in
which
the
attack
Chapman
describes
may
have
happened.
As
a
consequence,
the
video
does
not
provide
“irrefutable
evidence”
to
discredit
Chapman.
The
Court
must
take
his
version
of
events
as
true
at
the
summary
judgment
stage.
Under
the
facts
as
Chapman
tells
them,
a
reasonable
officer
would
not
have
used
the
force
Decker
and
Richert
did.
Considering
th
at
Chapman
was
compliant
with
officers’
instructions,
there
was
no
need
for
force
beyond
the
minimal
force
necessary
to
place
handcuffs
on.
Chapman
posed
no
security
threat
that
reasonably
called
for
the
force
used.
Further,
Chapman
suffered
pain
at
the
time
and
a
swollen
b
lack
eye
and
increased
seizure
activity
later.
A
reasonable
jury
could
find
that
the
force
Deck
er
and
Richert
used
against
Chapman
was
objectively
unreasonable.
Thus,
the
Court
ca
nnot
grant
summary
j
udgment
for
Decker
or
Richert
for
lack
of
evidence
on
this
aspect
of
Count
1.
2.
February
9,
2022:
Segregation
Cell
Incident
It
appears
that
Chapman
is
als
o
accusing
Decker,
and
possibly
Haring,
5
of
excessive
force
for
their
involvement
in
removing
the
ha
ndcuffs
once
he
reached
the
segregation
cell
on
the
morning
of
February
9,
2022.
Decker
was
working
with
Dawdy
and
Haring
to
place
Chapman
in
a
segregation
cell
immediately
after
th
e
incident
in
the
hallway.
Chapman
refused
to
comply
with
officers’
instructions
to
lay
down
on
the
floor,
so
Haring
applied
force
to
5
Haring
is
not
named
as
a
defendant
in
Count
1,
the
excessive
force
claim,
and
Chapman
never
sought
to
amend
his
complaint
to
include
him
as
an
excessive
force
defendant.
The
Court
considers
Haring’s
actions
anyway
because
th
e
defendants
addressed
such
a
claim
in
their
summary
judgment
motion
and
because
Haring
w
ould
be
entitled
to
summary
judgment
even
if
such
a
claim
had
been
pled.
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Chapman’s
legs
to
force
him
to
lay
down.
Chap
man
also
refused
instructions
to
keep
his
free
hand
on
the
floor
once
Dawdy
had
removed
the
left
handcuff
and
instead
tried
to
raise
up
from
the
floor.
Decker
applied
force
to
his
shoulder
to
try
to
keep
him
down,
and
when
Chapman
continued
to
try
to
raise
up,
Haring
sprayed
his
f
ace
with
a
short
burst
of
OC
spray.
No
evidence
shows
Dawdy
applied
any
force
other
that
what
was
necessary
to
uncuff
Chapman,
so
the
only
force
in
issue
is
Decker’s
and
Haring’s.
Again,
the
force
used
was
clearly
purposeful,
intended
to
force
compliance
with
instructions
to
allow
removal
of
handcuffs
from
an
aggressively
resisting
detainee
without
endangering
officers’
safety.
Further,
no
reasonable
jury
would
find
the
force
used
in
the
segregation
cell
unreasonable.
Unlike
in
the
hallway,
Chapman
was
resisting
commands
from
officers
to
comply
with
uncuffing
procedures
Jail
officials
deemed,
in
their
judgment,
necessary
to
maintain
security
and
officer
safety.
Decker,
Haring,
and
Dawdy
reasonably
perceived
that
Chapman
posed
a
risk
to
their
safety;
they
were
in
clos
e
quarters,
and
he
was
being
aggressive
and
yelling
threats.
The
force
Haring
and
Decker
used
was
reasonable
to
obtain
compliance
with
the
uncuffing
procedure.
Haring’s
force
on
Chapman’s
legs,
Decker’s
pressing
on
Chapman’s
shoulder,
and
Haring’s
short
burst
of
OC
spray
were
reasonable
where
Chapman
refused
to
comply
with
the
procedure
after
being
given
in
structions.
Their
force
was
limited
to
what
was
necessary
to
subdue
an
aggressive
and
threatenin
g
detainee
and,
indeed,
were
effective
to
accomplish
that
goal
without
violence
on
either
si
de.
Finally,
there
is
no
evidence
of
lasting
injury
to
Chapman,
only
short-term
OC
spray
expos
ure
that
he
was
told
to
rinse
off.
The
officers’
purposeful
conduct
was
objectively
reasonable,
so
the
Court
will
grant
summary
judgment
to
Decker
and
Haring
on
this
aspect
of
Count
1.
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3.
March
3,
2022:
Segregation
Cell
Incident
Chapman
claims
that
on
March
3,
2022,
Sellers
took
him
from
his
lockdown
cell
to
a
segregation
cell,
kicked
him
five
or
six
times
in
the
sides,
and
th
en
left
him
on
the
floor
of
the
segregation
cell,
where
he
remained
on
the
floor
for
several
days.
6
Sellers
claims
he
had
no
contact
with
Chapman
on
March
3,
2022,
and
that
there
was
no
incident.
However,
the
Court
must
take
the
events
as
Chapman
described
them
in
his
testimony.
The
facts
from
Chapman’s
testimony
show
that
Sellers
conduct
in
kicking
him
was
purposeful
and
that
such
force
was
not
justified
by
any
legitimate
reason.
Thus,
a
reasonable
jury
could
find
Sellers
liable
for
exce
ssive
force
for
the
March
3,
2022,
incident.
B.
Count
2:
Failure
to
Intervene
Chapman
claims
Dawdy
and
Foster
failed
to
intervene
to
stop
the
excessive
force
used
against
him
in
the
hallway
on
February
9,
2022.
An
officer
can
be
liable
for
failing
to
intervene
to
stop
the
excessive
force
of
another
when
he
has
reason
to
know
the
other
officer
is
using
excessive
force,
he
has
a
realistic
opportunity
to
in
tervene
to
prevent
the
harm,
and
he
fails
to
do
so.
Jackson
v.
City
of
Madison
,
176
F.4th
1005,
1016
(7th
Cir.
2026)
(citing
Lanigan
v.
Vill.
of
E.
Hazel
Crest
,
110
F.3d
467,
477
(7th
Cir.
1997)).
And
under
the
objective
standard
of
Kingsley
v.
Hendrickson
,
576
U.S.
389
(2015),
the
plaintiff
must
show
the
defendant
“intend[ed]
to
carry
out
a
certain
course
of
actions”
and
th
at
the
course
was
objectively
unreasonable.
Kemp
v.
Fulton
Cnty.
,
27
F.4th
491,
497
(7th
Cir.
2022)
(failure
to
protect).
Showing
negligence
is
not
enough.
Id.
In
other
words,
the
plaintiff
must
show
the
defendant
acted
purposefully,
knowingly,
or
recklessly
to
create
a
risk
for
the
plaintiff
when
a
r
easonable
officer
in
his
position
would
have
appreciated
the
ri
sk
and
acted
otherwise.
Pittman
by
&
through
Hamilton
v.
6
Chapman
does
not
complain
of
Decker’s
or
Richert’s
conduct
on
March
3,
2022.
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Madison
Cnty.,
Ill.
,
108
F.4th
561,
569
(7th
Cir.),
reh'g
denied,
No.
23-2301,
2024
WL
3889635
(7th
Cir.
Aug.
21,
2024),
and
cert.
denied,
145
S.
Ct.
1154
(2025).
1.
Dawdy
Dawdy
was
one
of
the
office
rs
participating
in
the
effort
to
handcuff
Chapman
in
the
hallway.
Chapman
does
not
complain
about
Dawdy’s
conduct
except
to
assert
that
he
failed
to
intervene
in
Decker’s
and
Richert’s
conduct.
He
argues
that
the
video
shows
he
was
on
the
ground
for
at
least
four
minutes,
which
would
ha
ve
given
Dawdy
a
reasonable
opportunity
to
intervene
to
stop
Decker’s
punching
and
Richert’s
kicking
Chapman.
Even
taking
as
true
Chapman’s
statements
th
at
Decker
and
Richert
used
excessive
force
against
him,
no
evidence
pushes
Chapman’s
f
ailure
to
intervene
claim
against
Dawdy
over
the
line
from
the
possible
to
the
probable
such
that
a
reasonable
jury
could
find
him
liable.
Nothing
Chapman
testified
to
could
lead
a
reasonable
ju
ry
to
conclude
that
Dawdy
made
a
purposeful,
knowing,
or
reckless
decision
not
to
intervene
to
st
op
Decker
or
Richert.
Further,
there
is
no
evidence
that
could
lead
the
jury
to
conclude
th
at
a
reasonable
officer
in
Dawdy’s
position
would
have
appreciated
the
risk
to
Chapman
of
excessive
force
in
what
the
Court
accepts
as
handcuffing
a
cooperative
detainee.
Nor
is
ther
e
evidence
that
a
reasonable
officer
in
Dawdy’s
circumstances
would
have
acted
any
differently
than
Dawdy
did.
“The
law
does
not
require
officers
to
act
as
fortune
tellers,
anticipating
when
their
fellow
officers
might
use
excessive
force
in
the
future
and
knowing
to
intervene
before
they
do.”
Stewardson
v.
Titus
,
126
F.4th
1264,
1279
(7th
Cir.
2025).
Chapman
describes
the
events
happening
in
fairly
quick
succession
to
an
unresisting
detainee.
Dawdy
was
busy
cuffing
Chapman’s
right
hand
at
or
near
the
time
Decker
hit
him
in
the
head
and
had
just
cuffed
Chapman’s
left
hand
when
Richert
kicked
him
in
the
eye.
No
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evidence
suggests
a
reasonable
officer
in
Dawdy’s
position
would
have
appreciated
that
Decker
or
Richert
posed
a
real
risk
of
using
excessive
force
on
Chapman
in
an
otherwise
cooperative
encounter
or
that
such
a
reasonable
officer
w
ould
have
chosen
to
abandon
the
task
of
handcuffing
Chapman
to
act
in
time
to
stop
any
unconstitutional
conduct.
The
fact
that
Chapman
was
on
the
ground
for
four
minutes
does
not
reasonably
lead
to
an
inference
that
Dawdy
or
a
reasonable
officer
in
Da
wdy’s
position
had
four
minutes
to
appreciate
the
risk
to
Chapman
and
to
intervene
in
a
way
that
could
have
stopped
Decker
or
Richert.
In
fact,
the
evidence
does
not
support
that
Dawdy
had
any
advance
notice
of
Decker’s
or
Richert’s
conduct,
and
without
advance
notice,
no
reasonab
le
officer
in
Dawdy’s
position
would
have
been
able
to
appreciate
the
risk
or
to
intervene
to
stop
it.
And
as
the
Seventh
Circuit
Court
of
Appeals
has
repeatedly
stated,
“summary
judgment
is
the
‘put
up
or
shut
up’
moment
in
the
life
of
a
case.”
AA
Sales
&
Assocs.
v.
Coni-Seal,
Inc.
,
550
F.3d
605,
612
(7th
Cir.
2008).
Chapman
has
simply
not
pointed
to
any
evidence
that
could
be
used
to
show
Dawdy
possessed
the
requisite
s
tate
of
mind
or
that
he
behaved
in
an
objectively
unreasonable
manner.
Accordingly,
the
Court
will
grant
summary
judgment
for
Dawdy
on
Count
2.
2.
Foster
Chapman
asserts
that
Foster
failed
to
intervene
in
the
use
of
excessive
force
when
Chapman
saw
him
in
the
hallway
as
he
was
being
walked
to
the
segregation
unit.
He
asked
Foster,
“Why
are
you
doing
this?”
and
asked
him
for
help.
Foster
replied,
“It
is
out
of
my
hands
and
I
am
sorry.”
Foster
did
not
enter
the
picture
until
af
ter—and
down
the
hall
from—Decker’s
and
Richers’s
alleged
use
of
excessive
force.
No
reasonable
jury
could
find
an
officer
in
Foster’s
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position
would
have
appreciated
the
danger
to
Chap
man
such
that
he
could
have
intervened
to
stop
it.
In
fact,
the
evidence
shows
he
was
only
aware
of
it
after
it
had
occurred.
Further,
to
the
extent
Chapman
believes
Foster
should
have
intervened
to
stop
any
excessive
force
once
Chapman
reach
the
segregation
unit,
there
is
no
evidence
that
any
force
was
excessive.
Without
excessive
force
,
an
officer
cannot
be
liable
for
failure
to
intervene
to
prevent
excessive
force.
Jackson
v.
City
of
Madison
,
176
F.4th
1005,
1016
(7th
Cir.
2026)
(first
element
of
failure
to
intervene
is
“that
excessive
force
was
being
used”);
Doxtator
v.
O’Brien
,
39
F.4th
852,
864-65
(7th
Cir.
2022).
And
no
facts
suggest
a
reasonable
officer
in
Foster’s
position
would
have
known
any
unconstitutional
force
was
p
lanned
to
be
perpetrated
in
the
segregation
unit.
There
was
simply
no
unconstitutional
conduct
that
needed
to
be
stopped,
and
to
the
extent
there
might
have
been,
an
officer
in
Foster’s
position
would
not
have
known
it
was
a
risk.
7
The
most
the
evidence
suggests
is
that
Foster
declined
to
intervene
in
a
security
response
he
was
not
involved
in
and
had
no
legitimate
reason
to
stop.
Indeed,
it
was
out
of
his
hands.
Because
no
evidence
suggests
Foster
beha
ved
in
an
objectively
unreasonable
way,
the
Court
will
grant
summary
judgment
for
him
on
Count
2.
C.
Count
3:
Medical
Care
Chapman
claims
Haring
responded
unreasonabl
y
to
his
medical
needs
by
placing
him
in
the
segregation
cell
on
February
9,
2022,
after
the
hallway
incident
and
after
spraying
him
with
OC
spray
without
summoning
medical
care.
To
prevail
on
this
claim,
Chapman
must
prove
he
suffered
from
an
objectively
serious
7
The
Court
does
not
intend
to
be
Pollyanna-ish;
it
knows
that
the
risk
of
excessive
force
is
always
present
in
the
correctional
environment.
But
a
reasonable
officer,
aware
of
its
prevalence,
must
still
have
some
reasonable
basi
s
to
believe
it
will
be
used
in
a
particular
circumstance
before
they
can
be
held
liable
for
the
failure
to
intervene.
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medical
need;
that
Haring
acted
purposefully,
know
ingly,
or
recklessly;
and
that
his
actions
were
objectively
unreasonable.
See
McGee
v.
Parsano
,
55
F.4th
563,
569
(7th
Cir.
2022);
James
v.
Hale
,
959
F.3d
307,
318
(7th
Cir.
2020);
Miranda
v.
Cnty.
of
Lake
,
900
F.3d
335,
352
(7th
Cir.
2018).
Where
the
plaintiff
sues
a
non-medical
defendant
for
in
adequate
medical
care,
the
Court
recognizes
the
circumstances
are
different
from
when
he
sues
a
medical
defendant.
This
is
because
jails
and
other
correcti
onal
facilities
often
separate
the
responsibilities
of
medical
professionals
to
provide
inmate
healthcare
from
those
of
other
security
or
administrative
staff
to
keep
the
institution
secure
and
in
good
order.
McGee
,
55
F.4th
at
569;
Miranda
,
900
F.3d
at
343.
“When
detainees
are
under
the
care
of
medical
experts,
non-medi
cal
jail
staff
may
generally
trust
the
professionals
to
provide
appropriate
medical
attention,”
Miranda
,
900
F.3d
at
343,
and
may
“defer
to
the
professional
medical
judgments
of
the
physicians
and
nurses
treating
the
[inmate]
in
their
care
wit
hout
fear
of
liability
for
doing
so,”
Berry
v.
Peterman
,
604
F.3d
435,
440
(7th
Cir.
2010).
This
is
so
unless
the
non-medical
officer
“had
reason
to
know
that
their
medical
staff
were
failing
to
treat
or
inadequately
treating
an
inmate.”
Miranda
,
900
F.3d
at
343.
“This
remains
true
even
when
an
inmate
is
in
obvious
distress
and
even
when
the
medical
staff
has
misdiagnosed
an
inmate—or
worse,
accused
him
of
faking
a
very
real
illness.”
McGee
,
55
F.4th
at
573
(citing
Miranda
,
900
F.3d
at
343).
Haring
first
contends
that
Chapman’s
medical
needs
were
not
serious.
The
Court
assumes
without
deciding
that
a
reasonable
jury
could
find
that
the
blows
Chapman
suffered
to
the
head,
his
history
of
brain
tr
auma
and
seizures,
and
the
OC
sprayed
in
his
face
would
constitute
a
serious
medical
need,
especially
wh
en
he
claimed
to
have
two
black
eyes,
a
bloody
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ear,
pain,
and
increased
seizure
activity,
and
when
he
was
given
treatment
the
following
day.
8
The
question
then
rests
on
whether
Haring’s
response
to
that
need
was
objectively
reasonable.
The
evidence
shows
that,
after
Chapman
was
placed
in
the
segregation
cell
and
was
sprayed
with
OC
spray,
Decker
instructed
Chapman
to
rinse
off
his
face
with
the
running
water
from
the
sink
in
his
cell.
D
ecker
also
informed
the
Jail
nursing
staff
of
the
incident
involving
Chapman.
Haring
did
nothing
himself
in
respon
se
to
Chapman’s
medical
plight.
Jail
medical
staff
saw
him
the
following
day,
February
10,
2022,
and
gave
him
Tylenol
and
ice
packs.
On
February
14,
2022,
Chapman
was
sent
for
a
CT
scan
of
the
head
where
the
doctor
noted
no
acute
fracture
or
joint
dislocation
and
unremarkable
soft
tissues.
The
Court
assumes
Haring
made
a
purposeful,
knowing,
or
reckless
decision
not
to
do
anything
more
to
obtain
medical
care
for
Chapman.
However,
a
reasonable
officer
in
Haring’s
position
would
not
have
contacted
the
Jail
med
ical
staff
for
treatment
of
Chapman
because
it
was
clear
another
officer
had
already
aske
d
medical
staff
to
see
Chapman
as
soon
as
they
could
safely
do
so.
Indeed,
someone
from
the
nursing
staff
sa
w
Chapman
the
following
day
to
evaluate
his
injuries.
Haring
was
entitled
to
rely
on
that
medical
staff
to
prope
rly
evaluate
and
treat
Chapman,
and
he
cannot
be
held
liable
for
any
shortcomings
on
their
part
such
as
a
delayed
response,
an
incomplete
exam,
or
improper
fo
llow-up
investigation
and
treatment.
Because
Haring
acted
reasonably
in
light
of
the
fact
that
the
medical
staff
had
already
been
alerted
that
Chapman
needed
care
and
he
could
rely
on
them
to
provide
that
care,
no
reasonable
jury
could
find
he
behaved
in
an
objectively
unreasonable
manner.
8
Chapman
complains
about
his
treatment
by
Jail
medical
staff,
but
he
did
not
sue
any
medical
personnel
in
this
case.
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D.
Qualified
Immunity
The
Court
addresses
the
question
of
qualified
immunity
as
it
applies
to
the
excessive
force
claims
that
have
survived
summary
judgment
so
far.
Qualified
immunity
is
an
affirmative
defe
nse
that
shields
governm
ent
officials
from
liability
for
civil
damages
where
their
conduct
do
es
not
violate
clearly
established
statutory
or
constitutional
rights
of
which
a
reasonable
officer
would
have
known.
Harlow
v.
Fitzgerald
,
457
U.S.
800,
818
(1982);
Zorn
v.
Linton
,
146
S.
Ct.
926,
930
(2026).
The
qualified
immunity
test
has
two
prongs:
(1)
whether
the
officer
violated
a
constitutional
right,
and
(2)
whether
the
right
at
issue
was
clearly
established
at
the
time
of
the
alleged
misconduct.
District
of
Columbia
v.
Wesby
,
583
U.S.
48,
62-63
(2018).
The
Court
turns
to
the
second
prong
as
applied
to
the
excessive
force
claims
that
have
elud
ed
summary
judgment
to
this
point.
Under
the
second
prong,
the
law
at
the
time
of
the
conduct
“must
have
placed
the
constitutionality
of
the
officer’s
conduct
beyond
debate”
such
that
“every
reasonable
official
would
understand
that
what
he
is
doing
is
unlawful.”
Wesby
,
583
U.S.
at
63
(internal
quotations
omitted);
accord
Zorn
,
146
S.
Ct.
at
930.
It
must
have
been
“settled
law,”
that
is,
it
must
have
been
“dictated
by
controlling
authority
or
a
robust
consensus
of
cases
of
persuasive
authority.”
Wesby
,
583
U.S.
at
63
(internal
quotations
omitted).
Generally,
this
requires
a
high
degree
of
specificity
in
the
precedent
so
that
every
reasonab
le
officer
would
have
been
alerted
to
the
law
in
the
particular
circumstances.
Zorn
,
146
S.
Ct.
at
930;
Wesby
,
583
U.S.
at
63.
“Principles
stated
generally,
such
as
that
‘an
officer
may
not
use
unreasonable
and
excessive
force,’
do
not
suffice.”
Zorn
,
146
S.
Ct.
at
930
(citing
Kisela
v.
Hughes
,
584
U.S.
100,
105
(2018)).
And
it
is
incumbent
on
the
plaintiff
to
show
the
clear
establishment
of
the
law
in
the
particular
circumstances,
but
the
failure
to
do
so
is
not
fatal
by
itself.
Taylor
v.
Schwarzhuber
,
132
F.4th
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480,
487
(7th
Cir.
2025).
Here,
the
issue
is
whether
it
was
clearly
established
that
a
defendant
can
use
force
on
a
pretrial
detainee
in
the
circumstances
shown
in
this
case.
The
defendants
take
the
position
in
their
motion
that
Chapman
was
actively
resisting
and
refusing
orders
on
February
9,
2022,
and
that
no
contact
even
occurred
on
March
3,
2022.
But
on
summary
judgment,
as
noted
earlier,
the
Court
must
take
the
plaintiff’s
testimony
as
true.
With
respect
to
the
February
9,
2022,
hallway
incident,
the
Court
assumes
Chapman
was
not
re
sisting
orders
to
facilitate
being
handcuffed
or
otherwise
being
unruly,
and
with
respect
to
the
March
3,
2022,
incident,
the
Court
assumes
Chapman
was
being
placed
in
a
segregation
cell
without
any
resistance.
Decker,
Richert,
and
Sellers
are
not
entitled
to
qualified
immunity
for
those
incidents.
The
evidence,
viewed
in
Chapman’s
favor,
showed
that
they
intentionally
and
gratuitously
used
force
to
cause
Chapman
pain.
But
in
2022,
it
was
clearly
established
that
the
gratuitous
use
of
force
to
inflict
pain
without
any
justification
was
unconstitutional
in
violation
of
the
Eighth
Amendment.
Leiser
v.
Kloth
,
933
F.3d
696,
703
(7th
Cir.
2019)
(Eighth
Amendment
prohibits
unnecessary
and
wanton
infliction
of
pain)
(citing
Calhoun
v.
DeTella
,
319
F.3d
936,
939
(7th
Cir.
2003);
Gregg
v.
Georgia
,
428
U.S.
153,
173
(1976)).
And
it
was
clear
then
that
pretrial
detainees
were
entitled
to
at
least
as
much
protection
under
the
Fourteenth
Amendment
Due
Process
Clause
as
convicted
criminals
were
under
the
Eighth
Amendment.
See
Belbachir
v.
Cnty.
of
McHenry
,
726
F.3d
975,
979
(7th
Cir.
2013).
Thus,
every
reasonable
jail
officer
would
have
understood
in
2022
from
Leiser
,
Calhoun
,
and
Gregg
that
purposeful
and
gratuitous
infliction
of
pain—such
as
punching
or
kicking
a
cooperating
pretrial
detainee—would
also
be
unconstitutional.
See
Johnson
v.
Rogers
,
944
F.3d
966,
970
(7th
Cir.
2019)
(under
objective
reasonableness
test,
“an
unnecessary
kick,
after
a
su
spect
is
under
control,
violates
the
suspect’s
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clearly
established
rights”);
Williams
v.
Stauche
,
709
F.
App’x
830,
836
(7th
Cir.
2017)
(“That
guards
cannot
gratuitously
abuse
prisoners
is
clearly
established.”).
The
court
in
Lee
v.
Bird
,
No.
4:22-cv-53-TWP-KMB,
2024
WL
621673,
at
*5-*6
(S.D.
Ind.
Feb.
14,
2024),
acknowledged
only
a
plainly
incompetent
office
would
not
have
understood
this
in
February
2022.
For
these
reasons,
Decker,
Richert,
and
Sellers
are
not
entitled
to
qualified
immunity.
E.
Injury
or
Causation
Finally,
the
defendants
argue
that
there
is
no
evidence
that
Chapman
suffered
any
injury
beyond
de
minimis
that
was
caused
by
the
defendants’
conduct.
They
point
to
Chapman’s
history
of
seizures
beginning
with
his
2016
gunshot
wound
to
the
head
and
its
treatment,
and
continuing
after
the
events
at
issue
in
this
case.
If
they
predated
the
events,
they
argue,
they
could
not
be
caused
by
them.
They
further
ar
gue
that,
to
the
extent
Chapman’s
seizures
increased,
it
was
due
to
other
factors
such
as
methamphetamine
withdrawal.
Finally,
they
suggest
that
Chapman
himself
was
to
blame
for
refusing
medications
prescribed
for
him
and
that
his
seizures
stopped
once
he
began
started
taking
an
adjusted
dose
of
the
medication.
Chapman
contends
that,
although
he
points
to
no
medical
evidence
of
causation,
his
testimony
of
injuries
to
his
head
and
face
as
well
as
increased
s
eizures
and
headaches
after
February
9,
2022,
is
sufficient
to
withstand
summary
judgment.
As
a
preliminary
matter,
the
Court
is
dismayed
that
the
defendants’
brief
for
this
section
lists
cases
that
either
do
not
exist
or
do
not
say
what
the
defendants
say
they
do.
See
Gutierrez
v.
Kermon
,
722
F.3d
1003,
1011
(7th
Cir.
2013)
(cited
for
th
e
proposition
that
“de
minimis
injuries
do
not
rise
to
the
level
of
a
constitutional
violation”;
actually
discussed
when
appellate
jurisdiction
exists
over
the
denial
of
qualif
ied
immunity
on
summary
judgment
in
Fourth
Amendment
case
and
did
not
address
de
minimis
injuries
at
all);
Estate
of
Allen
v.
City
of
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Chicago
,
No.
16-cv-8094,
2018
WL
4495982,
at
*4
(N.D.
Il
l.
Sept.
19,
2018)
(case
does
not
exist);
Williams
v.
Rodriguez
,
509
F.3d
392,
401
(7th
Cir.
2007)
(cited
for
the
proposition
that
since
Chapman’s
seizures
predate
the
use
of
force
a
sserted
in
this
case,
they
cannot
be
causally
linked
to
the
defendants’
conduct;
actually
discus
sed
whether
the
plaintiff’s
asthma
was
an
objectively
serious
medical
need
and
did
not
address
causation
of
injury
by
defendant’s
conduct);
Houskins
v.
Sheahan
,
549
F.3d
480,
495
(7th
Cir.
2008)
(cited
for
same
proposition;
actually
discussed
whether
state
law
claims
against
individual
defendant
were
properly
joined
for
trial
with
those
against
municipal
defendant
and
did
not
address
causation
of
injury
by
defendant’s
conduct).
Such
phenomena
are
becoming
more
frequent
in
the
age
of
generative
artificial
intelligence
(“AI”),
but
whether
these
mistakes
are
a
result
of
AI
or
other
error,
counsel’s
signature
under
Federal
Rule
of
Civil
Procedure
11(a
)
certifies
that
the
statements
in
her
brief
are
warranted
by
existing
law;
the
misstatements
listed
above
clearly
are
not.
The
Court
expects
far
better
from
defense
counsel,
who
has
regularly
and
ably
appeared
before
the
Court
for
decades.
Because
the
misrepresentations
at
issue
here
ar
e
immaterial
to
the
Court’s
decision
on
the
issue
in
question,
the
Court
declines
to
sanction
counsel
at
this
time.
However,
it
will
tolerate
no
more
such
sloppiness,
giving
it
the
most
generous
interpretation,
or
deceit,
giving
it
the
worst.
Should
counsel
or
her
law
firm
again
make
such
misrepresentations,
they
can
expect
to
be
sanctioned.
They
have,
of
course,
already
wasted
the
Court’s
time
chasing
down
fictitious
cases
or
holdings
and
have
lost
the
trust
of
this
Court.
As
for
the
merits
of
the
defendants’
arguments
,
it
is
true
that
injury
and
causation
are
essential
elements
of
a
§
1983
constitutional
tort.
See
Jackson
v.
Pollion
,
733
F.3d
786,
790
(7th
Cir.
2013);
Whitlock
v.
Brueggemann,
682
F.3d
567,
582
(7th
Cir.
2012).
But
even
a
de
minimis
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injury
will
support
constitutional
vi
olation
if
the
force
used
was
exce
ssive,
although
the
extent
of
the
injury
is
a
relevant
factor
to
consider
in
determining
whether
force
was
excessive.
9
Wilkins
v.
Gaddy
,
559
U.S.
34,
34,
37-38
(2010)
(
per
curiam
)
(“An
inmate
who
is
gratuitously
beaten
by
guards
does
not
lose
his
ability
to
pursue
an
ex
cessive
force
claim
merely
because
he
has
the
good
fortune
to
escape
without
serious
injury.”)
(citing
Hudson
v.
McMillian,
503
U.S.
1,
4
(1992)).
Indeed,
in
Hudson
,
the
plaintiff
was
similar
to
Cha
pman—he
had
been
punched
in
the
mouth,
eyes,
chest,
and
stomach
without
justification,
and
he
suffered
“minor
bruises
and
swelling
of
his
face,
mouth,
and
lip,”
loosened
teeth,
and
cracked
dental
hardware.
Hudson
,
503
U.S.
at
4.
Wilkins
was
similar—he
was
“punched,
kicked,
kneed,
choked,
and
body
slammed
maliciously
and
sadistically
and
without
any
provocat
ion”
and
suffered
“a
bruised
heel,
back
pain,
and
other
injuries
requiring
medical
treatment.”
Wilkins
,
559
U.S.
at
38.
In
light
of
Hudson
and
Wilkins
,
a
jury
could
easily
find
Chapman
suffered
injuries
to
his
face
and
head
that,
if
they
were
the
result
of
excessive
fo
rce,
would
support
his
constitutional
tort.
As
for
evidence
of
causation
by
the
defendants,
there
is
little
doubt
that
a
reasonable
jury
could
find
the
injuries
to
Chapman’s
face
and
head
were
caused
by
his
interactions
with
the
defendants
in
the
hallway
incident.
As
for
in
creased
seizure
activity,
while
Chapman
has
no
medical
evidence
of
causation,
he
is
competent
to
testify
to
the
increasing
frequency
of
his
own
seizures.
And
while
temporal
proximity
alone
may
not
be
enough
to
establish
a
genuine
issue
of
material
fact
on
causation
in
other
contex
ts
like
First
Amendment
retaliation,
see
Manuel
v.
Nalley
,
966
F.3d
678,
681
(7th
Cir.
2020),
the
Court
believ
es
it
may
be
sufficient
with
respect
to
the
conduct
in
this
case.
Here
the
defendants
inflicted
physical
trauma
on
the
head
of
a
detainee
9
In
contrast,
a
de
minimis
use
of
force
will
not
amount
to
an
Eighth
Amendment
violation
unless
such
force
is
“of
a
sort
repugnant
to
the
conscience
of
mankind.”
Hudson
,
503
U.S.
at
9-10;
see
O’Malley
v.
Litscher
,
465
F.3d
799,
805
(7th
Cir.
2006).
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who
had
preexisting
brain
injuries,
and
the
increased
frequency
of
seizures
followed
close
on
the
heels
of
that
trauma.
A
reasonable
jury
could
find
a
causal
connection.
It
is
for
the
defendants
to
argue
to
the
jury
that
no
such
connection
exists
and
that
the
increase
in
seizures
is
attributable
to
other
factors.
Because
a
reasonable
jury
could
find
Chapman
suffered
physical
injuries
and
increased
seizures
as
a
result
of
the
defendants’
use
of
ex
cessive
force,
the
Court
cannot
grant
summary
judgment
for
this
reason.
V.
Conclusion
For
the
foregoing
reasons,
the
Court:
x
DENIES
the
defendants’
motion
to
deem
admitted
the
facts
in
their
statement
of
material
facts
(Doc.
60);
x
GRANTS
in
part
and
DENIES
in
part
the
defendants’
motion
for
summary
judgment
(Doc.
54);
o
The
motion
is
GRANTED
to
the
extent
it
seeks
su
mmary
judgment
in
favor
of:
defendants
Decker
and
Haring
on
Count
1
for
excessive
force
within
the
Segregation
Unit
on
February
9,
2022;
defendants
Dawdy
and
Foster
on
Count
2
for
failure
to
intervene
on
February
9,
2022;
and
defendant
Haring
on
Count
3
for
placing
Chapman
in
a
segregation
cell
without
obtaining
medical
care
on
February
9,
2022;
o
The
motion
is
DENIED
to
the
extent
it
seeks
su
mmary
judgment
in
favor
of:
defendants
Decker
and
Richert
on
Count
1
for
excessive
force
in
the
hallway
on
February
9,
2022;
and
defendant
Sellers
on
Count
1
for
ex
cessive
force
on
March
3,
2022;
and
x
DIRECTS
the
Clerk
of
Court
to
enter
judgment
accordingly
at
the
close
of
the
case.
Defendants
Foster,
Dawdy,
and
Haring
are
TERMINATED
as
defendants.
Remaining
for
trial
are:
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x
Count
1
against
defendants
Decker
and
Richert
for
excessive
force
in
the
hallway
on
February
9,
2022;
and
x
Count
1
against
defendant
Sellers
for
excessive
force
on
March
3,
2022.
The
Court
will
set
a
telephone
status
conference
by
separate
order
to
pick
dates
for
the
Final
Pretrial
Conference
and
Trial.
10
IT
IS
SO
ORDERED.
DATED:
July
10,
2026
__________________________________
J.
PHIL
GILBERT
DISTRICT
JUDGE
10
In
his
response
to
the
summary
judgment
motion,
Chapman
asks
to
reopen
discovery
to
obtain
additional
video
footage
and
to
conduct
additional
depositions.
It
is
not
proper
to
make
such
a
request
within
a
response
brief;
it
should
have
been
raised
by
separate
motion
explaining
why
such
discovery
could
not
have
been
conducted
before
the
discovery
deadline
of
September
10,
2025
(Doc.
50).
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