Gonzales v. McHenry County, Illinois

Dist. Ct. did not err in granting defendants-jail officials and County’s motion to dismiss plaintiff-deceased prisoner’s section 1983 action, alleging that defendants violated his rights by: (1) maintaining official jail policy, which required that defendants accept all prisoners who could not obtain pre-trial release without regard of ability of jail to accommodate prisoner’s serious medical needs; (2) defendants knew that jail could not accommodate decedent’s medical needs and ignored them; and (3) decedent died two months after he was transferred to different facility. Plaintiff could not proceed against defendant-Sheriff, where plaintiff failed to allege that Sheriff had knowledge of plaintiff’s detention or his medical condition, and where there was no allegation that jail personnel did not promptly respond to plaintiff’s medical incidents throughout his incarceration. Also, plaintiff could not pursue his Monell claim against defendant-County, where: (1) plaintiff failed to allege existence of Sheriff’s Department policy, since courts, and not Sheriff, make pre-trial detention decisions; and (2) Sheriff Department had no option but to detain decedent in its jail and had no policymaking authority over purported policy alleged by plaintiff. Moreover, Ct. noted that decedent always had option to petition court for release based on extraordinary medical grounds.