Smith v. Sangamon County Sheriff’s Dept.

Dist. Ct. did not err in granting defendants-jail officials’ motion for summary judgment in plaintiff-prisoner’s section 1983 action alleging that defendants’ approach to classifying inmates for cellblock placement, which failed to separate violent from non-violent inmates, constituted violation of plaintiff’s due process rights where plaintiff, as non-violent inmate, was attacked by violent cellmate. Plaintiff failed to present evidence that instant security classification policy, which used multiple factors including prior incarceration history at jail, systematically failed to address obvious risks to inmate safety. Moreover, plaintiff failed to present any evidence that defendants either had notice of particular harm to plaintiff resulting from placement in particular cell or knew that instant classification system exposed plaintiff to any serious risk of harm.