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Charles Flynn v. Natasha Lawson, et al. - Prisoner Complaint Dismissed for Pleading Deficiencies

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Summary

Charles Flynn, proceeding pro se, filed a 32-page handwritten amended complaint in the United States District Court for the Central District of Illinois against twenty named defendants including state police and prison officials (docket 3:25-cv-03385). The Court screened the complaint under 28 U.S.C. § 1915A and dismissed it for pleading deficiencies, finding the factual allegations — relating to a fight with another inmate, a guard kicking Plaintiff's shoes, and theft of property — failed to state a claim that is plausible on its face and improperly joined unrelated claims against multiple defendants. The Court applied the pleading standards from Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, and the joinder rules under Rules 18 and 20 of the Federal Rules of Civil Procedure.

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GovPing monitors US District Court CDIL Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 8 changes logged to date.

What changed

The Court applied the screening standard under 28 U.S.C. § 1915A to a pro se prisoner's amended complaint and dismissed it in its entirety. The complaint alleged three unrelated sets of facts: (1) an inmate assault and inadequate investigation, (2) a guard's physical contact with Plaintiff's shoes, and (3) failure to investigate stolen property — none of which were adequately connected legally. The Court held the allegations failed to meet the Bell Atlantic v. Twombly / Ashcroft v. Iqbal plausibility standard, and that the joinder of claims and defendants violated Rules 18 and 20 of the Federal Rules of Civil Procedure.

For prison litigation practitioners and pro se filers, this order reinforces the heightened pleading obligations under the Prison Litigation Reform Act (PLRA), specifically: complaints must allege facts — not conclusory statements or labels — that are plausible on their face; each defendant must be connected to the alleged constitutional violation through personal participation; and unrelated claims against different defendants arising from separate transactions must be severed into separate actions rather than combined in one complaint. Plaintiffs proceeding pro se retain liberal construction of their filings, but must still satisfy the Twombly plausibility threshold.

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Apr 25, 2026

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April 23, 2026 Get Citation Alerts Download PDF Add Note

Charles Flynn v. Natasha Lawson, et al.

District Court, C.D. Illinois

Trial Court Document

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
SPRINGFIELD DIVISION

CHARLES FLYNN, )
)
Plaintiff, )
)
v. ) 3:25-cv-03385-MMM
)
NATASHA LAWSON, et al., )
)
Defendants. )

ORDER
Plaintiff, proceeding pro se, seeks to allege claims in this Court.
The Court must “screen” Plaintiff’s complaint, and through such process identify
and dismiss any legally insufficient claim, or the entire action if warranted. 28 U.S.C. §
1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a
claim upon which relief may be granted; or (2) seeks monetary relief from a defendant
who is immune from such relief.” Id.
The Court accepts the factual allegations as true, liberally construing them in the
plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (7th Cir. 2013). Conclusory
statements and labels are insufficient—the facts alleged must “state a claim for relief
that is plausible on its face.” Alexander v. United States, 721 F.3d 418, 422 (7th Cir. 2013)
(citation omitted).
Allegations
Plaintiff’s names twenty Defendants including state police officials and prison
officials. He alleges several sets of facts that are not clearly connected.
One set of allegations relates to a fight with another inmate. In that set of
allegations Plaintiff alleges another inmate attacked him. Plaintiff was not an aggressor

in the fight. He was disciplined for the fight anyway and punished with reduced
privileges and seven days segregation confinement. A no contact order was put in place
so the inmate who attacked him would not be near him. Plaintiff alleges the assault was
not properly investigated, the person who assaulted him was not properly punished or
criminally charged. An officer violated the no contact order by placing Plaintiff and the
person who attacked him next to each other at a meal, and telling Plaintiff they would

not be separated and should “fight or fuck.” There was no physical altercation.
Another allegation relates to a guard kicking or stepping on the back of
Plaintiff’s shoes as he left the dietary hall one day.
Another allegation relates to a different inmate stealing Plaintiff’s property and
prison officials failing to properly investigate the matter.

There may be other allegations woven into Plaintiff’s thirty-two page amended
complaint, which is densely handwritten, but these are the apparent allegations.
Pleading Standards
“Only persons who cause or participate in [constitutional] violations are
responsible.” George v. Smith, 507 F.3d 605, 609 (7th Cir. 2007). The Federal Rules of Civil

Procedure require that the plaintiff submit a short and plain statement of the claim
showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2). The Seventh Circuit
has consistently noted that the essential function of a complaint under the civil rules ...
is to put the defendant on notice of the plaintiff’s claim. Ross Brothers Const. Co., Inc, v.
International Steel Services, Inc., 283 F.3d 867, 872 (7th Cir. 2002) (quoting Davis v. Ruby
Foods, Inc., 269 F.3d 818, 820 (7th Cir. 2001)). While it is not necessary for a plaintiff to

plead specific facts, Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007), “[t]hreadbare
recitals of the elements of a cause of action, supported by mere conclusory statements,
do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2007) (citing Twombly, 550 U.S. at 555)
(observing that courts “are not bound to accept as true a legal conclusion couched as a
factual allegation”).
Joinder of Claims

“A prisoner may join Defendants in the same action only if the claims against
each one ‘aris[e] out of the same transaction, occurrence, or series of transactions or
occurrences ….” Mitchell v. Kallas, 895 F.3d 492, 502–03 (7th Cir. 2018) (quoting Fed. R.
Civ. P. 20(a)(2)). “Joinder that requires the inclusion of extra parties is limited to claims
arising from the same transaction or series of related transactions.” Wheeler v. Wexford

Health Sources, Inc., 689 F.3d 680, 683 (7th Cir. 2012). “To be precise: a plaintiff may put
in one complaint every claim of any kind against a single defendant, per Rule 18(a), but
a complaint may present claim #1 against Defendant A, and claim #2 against Defendant
B, only if both claims arise ‘out of the same transaction, occurrence, or series of
transactions or occurrences.’” Wheeler v. Wexford Health Sources, Inc., 689 F.3d 680, 683 (7th Cir. 2012) (quoting Rule 20(a)(1)(A)).
“[D]istrict courts should not allow inmates to flout the rules for joining claims
and Defendants, see Fed. R. Civ. P. 18, 20, or to circumvent the Prison Litigation Reform
Act’s fee requirements by combining multiple lawsuits into a single complaint.” Owens
v. Godinez, 860 F.3d 434, 436 (7th Cir. 2017).

The Seventh Circuit “target[s] for dismissal ‘omnibus’ complaints—often
brought by repeat players—that raise claims about unrelated conduct against unrelated
Defendants.” Mitchell, 895 F.3d at 503. However, “judges may sever unrelated claims
into separate suits (rather than dismiss the claims) if the statute of limitations has
otherwise lapsed.” Morris v. Kulhan, 745 F. App’x 648, 649 (7th Cir. 2018).
Finally, even claims that are properly joined may be severed in an exercise of the

Court’s discretion, where doing so would be in the interests of justice and would
promote the efficient and effective resolution of all claims.
Analysis
Plaintiff’s pleadings are neither short nor plain, and so do not meet the
requirements of Rule 8. Plaintiff also does not allege the direct personal involvement of

many of the Defendants that he has named. These pleading deficiencies call for
dismissal of the amended complaint.
Plaintiff’s pleadings also appear to run counter to the joinder rules. Plaintiff tries
to combine issues that are unrelated to one another. If he moves to amend, any
proposed amended complaint must comply with the joinder rules described above. If

Plaintiff wants to sue different Defendants about things that happened on different
days, he needs to file separate lawsuits to do so.
Substantively, Plaintiff’s allegations also do not state a claim.
Plaintiff discusses various issues regarding Freedom of Information Act requests
he made to state officials. There is no private right of action in federal court for issues

regarding FOIA requests to state agencies. See Belk v. Watson, No. 19-CV-00499-JPG, 2019 WL 2188905, at *3 (S.D. Ill. May 21, 2019).
Likewise, the Prison Rape Elimination Act does not allow for a private lawsuit.
See Closson v. Kohlhepp, No. 21-cv-772, 2021 WL 3363139, at *2 (S.D. Ind. Aug. 3, 2021).
As to Plaintiff’s allegations that the Illinois State Police and prison investigators
did not respond properly to his requests for an investigation of the attack he suffered,

the Court fully appreciates Plaintiff’s frustration. But there is no free-standing
constitutional right to an investigation by prison officials or the state police after an
occurrence like the fight that Plaintiff was injured in, nor is there a constitutional right
for criminal charges to be filed against a wrongdoer. There is no allegation here that any
prison official knew that Plaintiff was facing an imminent risk of serious harm and

could have done anything about it before Plaintiff was attacked.
Plaintiff alleges that later, prison guards allowed an internal prison no contact
order to be violated by allowing or causing Plaintiff and the person who previously
attacked him to be seated next to one another at a meal. But there is no indication that
Plaintiff was attacked or injured again, nor that there was any other harm done at that

time. A violation of a prison directive, rule, administrative code, or even a state law
does not on its own indicate or necessarily support an inference that a violation of the
United States Constitution occurred.
Plaintiff alleges a prison guard said Plaintiff had to “fight or fuck.” And he
alleges that on another occasion a guard stepped on or kicked at the backs of his shoes.

These are unpleasant allegations but alone do not spell out a violation of the
constitution. Coarse language and minor affronts such as the issue with the stepping on
or kicking at shoes are not ideal behavior by corrections staff. But every affront,
inconvenience, or unpleasantness experienced in prison is not the basis for a federal
lawsuit, particularly where, as here, Plaintiff has not alleged that he was injured or
harmed as a result of these actions by corrections staff.

As to Plaintiff’s allegations that he received a wrongful disciplinary ticket, that
the disciplinary hearing was effected without proper process, and that Plaintiff was
wrongfully punished, none of these allegations state a claim for relief, because Plaintiff
has not alleged that the punishment that he received rose to a level protected by the due
process clause of the Constitution. Plaintiff is already in prison. His liberty is almost

completely curtailed based on his criminal sentence. To allege a deprivation of liberty
sufficient to warrant due process protections, an extended period in segregation, the
loss of good time credits, or some other atypical and extreme additional conditions of
confinement must have been imposed. Otherwise, there is no entitlement to due process
because there is no cognizable deprivation of liberty over and above Plaintiff’s already

lawfully much-curtailed liberty. Earl v. Racine Cty. Jail, 718 F.3d 689, 691 (7th Cir. 2013).
Again, the Court takes seriously Plaintiff’s allegation that he was attacked by
another prisoner, and understands how upset Plaintiff is that after that experience, he
was disciplined, that he does not believe the issue was properly investigated, and that
he experienced additional issues that he believes are unfair. But accepting all those
things as true, Plaintiff’s allegations do not state a federal claim.
IT IS THEREFORE ORDERED:

  1. Pursuant to its merit review of the Complaint under 28 U.S.C. § 1915A, the Court finds that Plaintiff has failed to state a claim for relief. Plaintiff's remaining allegations are too vague and non-specific to put any Defendant on notice of a federal claim. Plaintiff's Complaint is DISMISSED without prejudice for failure to state a claim.
  2. The Court will allow Plaintiff the opportunity to file a motion for leave to amend with an attached proposed Amended Complaint, within 28 days of this Order. Failure to file an Amended Complaint will result in the dismissal of this case, without prejudice, for failure to state a claim. Entered this 23rd day of April, 2026. s/Michael M. Mihm MICHAEL M. MIHM UNITED STATES DISTRICT JUDGE

Named provisions

28 U.S.C. § 1915A Federal Rule of Civil Procedure 8(a)(2) Federal Rule of Civil Procedure 20(a)(2) Federal Rule of Civil Procedure 18(a)

Citations

28 U.S.C. § 1915A authority for prisoner complaint screening standard

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Last updated

Classification

Agency
USDC CDIL
Filed
April 23rd, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Docket
3:25-cv-03385

Who this affects

Applies to
Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Civil rights litigation Prisoner complaint screening Federal court procedure
Geographic scope
Illinois US-IL

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Criminal Justice

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