VINCENT v. BARTHOLOMEW COUNTY JAIL et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
INDIANAPOLIS DIVISION
JOSEPH VINCENT, 	)
)
Plaintiff, 	)
)
v. 	) 	No. 1:26-cv-01659-JRO-CSW
)
BARTHOLOMEW COUNTY JAIL, 	)
OLDHAM, 	)
MATHIS, 	)
ELLIOTT, 	)
PITCHER, 	)
TURNER, 	)
MUNN, 	)
CHRIS LANE, 	)
)
Defendants. 	)
ORDER SCREENING COMPLAINT AND DIRECTING FURTHER
PROCEEDINGS
Plaintiff Joseph Vincent filed this civil rights complaint pursuant to 42
U.S.C. § 1983 while he was a pretrial detainee at Bartholomew County Jail,
alleging 	that 	Defendants 	violated 	his Fourteenth 	Amendment 	right 	to 	due
process of law by placing him in solitary confinement without a hearing. Dkt. 1.
Because Vincent was a "prisoner" when he filed the complaint, the Court must
screen his complaint before the case may proceed. 28 U.S.C. § 1915A(a), (c).
Additionally, the Court takes notice that its last order was returned as
undeliverable since Vincent is no longer at the address listed on the docket. Dkt.
16. The Court notified Vincent of his obligation to update the Court with any
address changes, including discharge from custody. Dkt. 4. Accordingly, Vincent
is ORDERED to update his address by November 6, 2026. If Vincent fails to
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meet the above deadline, this action will dismissed for failure to prosecute
without further notice or opportunity to show cause.
I. SCREENING STANDARD
When screening a complaint, the Court must dismiss any portion that is
frivolous or malicious, fails to state a claim for relief, or seeks monetary relief
against a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). To
determine whether the complaint states a claim, the Court applies the same
standard as when addressing a motion to dismiss under Federal Rule of Civil
Procedure 12(b)(6). See Schillinger v. Kiley, 954 F.3d 990, 993 (7th Cir. 2020).
Under that standard, a complaint must include "enough facts to state a claim to
relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570
(2007). "A claim has facial plausibility when the plaintiff pleads factual content
that allows the court to draw the reasonable inference that the defendant is liable
for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The
Court construes pro se complaints liberally and holds them to a "less stringent
standard than pleadings drafted by lawyers." Cesal v. Moats, 851 F.3d 714, 720
(7th Cir. 2017).
II. THE COMPLAINT
Vincent's 	factual 	allegations 	are 	accepted 	as 	true 	at 	the 	pleading
stage. See Lisby v. Henderson, 74 F.4th 470, 472 (7th Cir. 2023). Vincent names
the following as Defendants: (1) Bartholomew County Jail; (2) Ofc. Oldham; (3)
Ofc. Mathis; (4) Ofc. Elliott; (5) Ofc. Pitcher; (6) Ofc. Turner; (7) Ofc. Munn; and
(8) Sheriff Chris Lane. Dkt. 1.
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On July 9, 2026, Vincent was transferred from general population in
Bartholomew County Jail to a segregation unit because correctional officers
claimed that he was the aggressor in a verbal argument with another inmate. Id.
at 1. As of July 31, 2026, Vincent was still being held in the segregation unit
without having had a write-up or a hearing. Id. In the segregation unit, he did
not receive recreation, and he did not have access to natural light. Id. Vincent
filed grievances and spoke to several correctional officers, including Ofc. Elliott,
Ofc. Mathis, Ofc. Munn, Ofc. Pitcher, and Ofc. Turner, but no one did anything.
Id. at 1–2. While in segregation, Vincent injured his knee, but he had no way to
treat it because he could not move around in or outside of his cell. Id. at 2.
On information and belief, Vincent alleges that Sheriff Chris Lane has a
practice 	of 	holding 	pretrial 	detainees 	in 	segregation 	without 	a 	disciplinary
proceeding or a hearing. Id. at 2–3. While Vincent was held in segregation, he
encountered another pretrial detainee who was being held without a disciplinary
proceeding. Id. at 3.
Vincent 	suffered 	physical 	and 	mental 	injuries 	while 	being 	held 	in
segregation. See id. at 2–3. He seeks monetary damages. Id. at 3.
III. DISCUSSION OF CLAIMS
Vincent's allegations invoke the Fourteenth Amendment's Due Process
Clause, which provides that State officials shall not "deprive any person of life,
liberty, or property, without due process of law." U.S. Const. amend. XIV. Here,
Vincent alleges that correctional officers deprived him of liberty by placing him
in segregation without due process of law. The Seventh Circuit has considered
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"any nontrivial punishment of a person not yet convicted a sufficient deprivation
of liberty to entitle him to due process of law." Holly v. Woolfolk, 415 F.3d 678,
679−80 (7th Cir. 2005). In general, the Due Process Clause does not confer a
right to a pre-deprivation hearing in every case where a public officer deprives
an individual of liberty or property. Ellis v. Sheahan, 412 F.3d 754, 758 (7th Cir.
2005); see, e.g., Halligan v. Oldham, No. 24-1481, 2025 WL 1289343, at *2 (7th
Cir. May 5, 2025) ("[N]o process is due when a detainee is placed in segregation
for nonpunitive reasons such as institutional safety or security."). However, "[a]
pretrial 	detainee 	cannot 	be 	placed 	in 	segregation 	as 	a 	punishment 	for 	a
disciplinary infraction without notice and an opportunity to be heard; due
process requires no less." Higgs v. Carver, 286 F.3d 437, 438 (7th Cir. 2002).
Applying the legal standard to the factual allegations in the complaint,
certain claims are dismissed while other claims shall proceed as submitted.
First, the Court dismisses claims against Bartholomew County Jail because it
is a building and not a "person" that can be sued under 42 U.S.C. § 1983. See
Smith v. Knox County Jail, 666 F.3d 1037, 1040 (7th Cir. 2012) ("[T]he district
court was correct that, in listing the Knox County Jail as the sole defendant,
Smith named a non-suable entity.").
Second, the Court dismisses claims against the individual correctional
officers, Ofc. Oldham, Ofc. Mathis, Ofc. Elliott, Ofc. Pitcher, Ofc. Turner, and
Ofc. Munn. Though the complaint alleges that Vincent complained to these
officers about his placement in segregation, there are no allegations showing that
any 	of 	the 	officers 	caused 	him 	to 	be 	placed 	in 	segregation 	or 	remain 	in
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segregation. To state a claim under Section 1983, Vincent has to show that each
Defendant was personally involved in violating his constitutional rights. Colbert
v. City of Chicago, 851 F.3d 649, 657 (7th Cir. 2017). Specifically, "[t]he plaintiff
must demonstrate a causal connection between (1) the sued officials and (2) the
alleged misconduct." Id. Mere "knowledge of a subordinate's misconduct is not
enough for liability." Vance v. Rumsfeld, 701 F.3d 193, 203 (7th Cir. 2012) (en
banc). Indeed, "inaction following receipt of a complaint about someone else's
conduct is [insufficient]." Est. of Miller by Chassie v. Marberry, 847 F. 3d 425,
428 (7th Cir. 2017); see Burks v. Raemisch, 555 F.3d 592, 595 (7th Cir. 2009)
("[The plaintiff's] view that everyone who knows about a prisoner's problem must
pay damages implies that he could write letters to the Governor . . . and 999
other public officials, demand that every one of those 1,000 officials drop
everything he or she is doing in order to investigate a single prisoner's claims,
and then collect damages from all 1,000 recipients if the letter-writing campaign
does not lead to better medical care. That can't be right."). Thus, it is not enough
to allege that Defendants were aware that Vincent was in segregation without a
disciplinary hearing; they must have caused him to be placed or remain there.
Vincent's Fourteenth Amendment claim against Sheriff Chris Lane shall
proceed as a Monell claim. See Monell v. Dep't of Soc. Servs. of City of New York,
436 U.S. 658 (1978); Levy v. Marion Cnty. Sheriff, 940 F.3d 1002, 1010 (7th Cir.
2019) (applying Monell to claim against Sheriff's Department)). At the pleading
stage, Vincent has alleged that the Sheriff or the Sheriff's Office had a policy or
practice of placing pretrial detainees in segregation without a hearing.
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This summary of claims includes all the viable claims identified by the
Court. All other claims have been dismissed. If Vincent believes that additional
claims were alleged in the complaint, but not identified by the Court, he shall
have through November 6, 2026, in which to file a motion to reconsider the
screening order.
IV. CONCLUSION AND SERVICE OF PROCESS
Fourteenth Amendment due process claims are proceeding against Sheriff
Chris Lane under the Monell theory of liability. All other claims have been
dismissed.
The clerk is directed to terminate Bartholomew County Jail, Elliott,
Mathis, Munn, Oldham, Pitcher, and Turner as defendants on the docket.
The clerk is directed pursuant to Fed. R. Civ. P. 4(c)(3) to issue process
to Defendant Lane in the manner specified by Rule 4(d). Process shall consist of
the complaint filed on August 6, 2026, dkt. [1], applicable forms (Notice of
Lawsuit and Request for Waiver of Service of Summons and Waiver of Service of
Summons), and this Order.
Nothing in this Order prohibits the filing of a proper motion pursuant to
Rule 12 of the Federal Rules of Civil Procedure.
Additionally, 	the 	Court 	takes 	notice 	that 	the 	Court's 	last 	order 	was
returned as undeliverable since Vincent is no longer at the address listed on the
docket. Dkt. 16. The Court notified Vincent of his obligation to update the Court
with 	any 	address 	changes, 	including 	discharge 	from 	custody. 	Dkt. 	4.
Accordingly, Vincent is ORDERED to update his address by November 6, 2026.
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If Vincent fails to meet the above deadline, this action will dismissed for failure
to prosecute without further notice or opportunity to show cause.
SO ORDERED.
Date: 10/9/2026
Distribution:
JOSEPH VINCENT
1314 Lafayette Ave
Apt. 4
Columbus, IN 47201
SHERIFF CHRIS LANE
BARTHOLOMEW COUNTY JAIL
543 2nd St.
Columbus, IN 47201
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