Former Detainee Alleges Unconstitutional Conditions at Illinois Jail, Accepts $7,501 Judgment
On April 24, 2013, the Seventh Circuit Court of Appeals held that a former pretrial detainee at the Edgar County Jail (ECJ) in Illinois stated a claim concerning unconstitutional conditions of confinement at the facility. The appellate court also affirmed the dismissal of a claim alleging deliberate indifference to the detainee’s medical needs.
Over a period of two-and-a-half years, Richard D. Budd served three stints at ECJ as a pretrial detainee. He initially spent 45 days at the jail following a 2009 arrest. During that time he was confined with eight other detainees in an area of the facility intended for three; he had to sleep on the floor alongside broken windows and damaged toilets.
After another arrest two years later, Budd was placed in a section of the ECJ where overcrowded conditions again forced him and other prisoners to sleep on the floor amid water from a shower leak. The cells had broken windows, exposed wiring, extensive rust, sinks without running water, toilets covered in mold and spider webs, and a broken heating system. ECJ staff did not provide prisoners with cleaning supplies.
Four months later, Budd was again arrested and had to sleep on the floor in an ECJ cellblock. The cell’s vents were blocked, the heating and air conditioning systems did not work, and detainees were denied recreation. While living in these conditions, something scratched or bit Budd’s leg, resulting in an infection and swelling. He was taken to a local hospital for treatment after contacting the Sheriff.