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Are Edgar County Jail Conditions Cruel and Unusual?

By Robyn Hagan Cain | Last updated on

No one ever said that a jail cell should be comfortable, but Richard Budd claims in a civil rights lawsuit that pretrial detention conditions in the Edgar County, Illinois Jail were downright unlivable.

Budd alleges that he was subject to unconstitutional conditions of confinement as an Edgar County pretrial detainee, and that the sheriff was deliberately indifferent to his medical needs. After a video conference to screen Budd’s complaint, the district court dismissed his action for failure to state a claim. The court, however, never prepared a transcript of the proceedings and it failed to issue a written statement of reasons for the decision.

According to the Seventh Circuit Court of Appeals, Budd’s claims were actionable.

Budd spent 45 days in the Edgar County Jail following a 2009 arrest. According to newspaper articles that accompanied his complaint, Sheriff Edward Motley described the jail as not "livable" and violating "acceptable standards." Budd claims that he was one of nine inmates living in a space meant for three, and he had to sleep on the floor "alongside broken windows and cracked toilets."

Two years later, when Budd returned to the jail after another arrest, he says conditions were even worse. Following a third arrest, Budd developed an infection after he was bitten or scratched while in the jail.

Conditions in the jail sound pretty wretched, so it's no surprise that the Seventh Circuit agreed that Budd alleged conditions that state a claim for relief. The appellate court noted that Budd alleged a real harm based on unhygienic conditions. His civil rights complaint was also supported by claims of improper heating, overcrowding, and poor air circulation.

While the fact that Budd received medical attention for his mystery bite/scratch undermines his medical indifference claim, the Seventh Circuit Court of Appeals reversed and remanded the remaining claims to the district court.

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