Illinois State Duty to Provide Prisoners With Safe Conditions

Holt v. State (1990) summarizes the general principle that the State owes a duty to inmates to provide them with safe conditions under which to perform their assigned work, or more, broadly interpreted to include safe living conditions. Holt v. State, 43 Ill. Ct. Cl. 195. However, the case does not address issues of the use of force and does not provide specific guidance for the issues in the case at bar. In Simmons v. State (1991), the claimant alleged use of excessive force by the State. Simmons, 44 Ill. Ct. Cl. 304. The Court found that the officers, used such force and compulsion as was necessary to restrain claimant and to protect officers and Claimant from additional, further, or more serious injuries. Id, at 306-7. In Hamilton v. State (1987), 40 Ill. Ct. Cl. 191, an officer fired a warning shot into the ceiling of the dining room because of a fight between another officer and an inmate. Claimant was not involved in the fight, however, he was struck in the face by ricocheted shotgun pellets. The allegations made by Hamilton were consistent with the allegations raised in the case at bar. The Hamilton Court found that the firing of the shotgun constituted the use of deadly force under DOC's Rules. The Court accepted the judgment of the officer in his determination that the disturbance was serious enough to warrant the firing of the warning shot. The Court stated that an officer in that situation has a wide range of discretion. Even if he exercised bad judgment, this is not necessarily exceeding the limits of his discretion, or abusing his discretion, the Court reasoned Id. at 195. The Court concluded that the officer's conduct did not support a claim for negligence.