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E-FILED
E-FILED

Monday,
Sunday, 12
11 March,
March, 2018
2018 10:30:41
06:27:44 AM
PM
Clerk,
Clerk, U.S.
U.S. District
District Court,
Court, ILCD
ILCD
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
)
)
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)
)
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)
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KELLI ANDREWS, as Administrator
of the
Estate of Tiffany Ann Rusher,
deceased,
Plaintiff,
v.
SANGAMON COUNTY, ILLINOIS,
WES BARR, LARRY BECK JR., and
DOES 1-5,
Defendants.

Case No. ___________

JURY TRIAL DEMANDED

COMPLAINT

COMES NOW Plaintiff, Kelli Andrews, by and through counsel, for her
Complaint against Sangamon County, Wes Barr, Larry Beck Jr., and Does 1-5
(collectively, “Defendants”), and states as follows:
I.
1.

NATURE OF THE ACTION

Tiffany Rusher, who was a pre-trial detainee in the Sangamon County

Detention Facility (“Sangamon Jail”), suffered from severe mental illness. When
she entered the Sangamon Jail in December 2016, the Defendants knew that she
was severely mentally ill, that she was at high risk of suicide, and that she was in
need of intensive mental health treatment. The defendants also knew, or at the
very least should have known, that placing a person with Tiffany’s mental state in
solitary confinement would only exacerbate her deteriorated mental condition,
cause severe psychological trauma, and make it more likely that Tiffany would try
to kill herself.
2.

Nevertheless, the defendants placed Tiffany in solitary confinement,

and kept her there for more than three months. This solitary confinement caused
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Tiffany’s mental condition to deteriorate further, but the defendants failed to
provide Tiffany with adequate mental health treatment, compounding the harmful
effects of solitary and increasing the chance that she would try to harm herself.
3.

What is more, the defendants failed to take adequate steps to guard

against the possibility of suicide, making it easier for Tiffany to harm herself
severely. As a direct result of defendants’ actions and failures to act, Tiffany was
found asphyxiated in her cell on March 18, 2017. She died on March 30, 2017, after
spending 12 days on life support.
4.

This is an action for compensatory, nominal, and punitive damages,

with claims brought under the Fourteenth Amendment to the United States
Constitution pursuant to 42 U.S.C. § 1983, the Americans with Disabilities Act
(“ADA”), and the Rehabilitation Act (“RA”) to redress violations of Tiffany’s rights.
Plaintiff also asserts claims against the Defendants pursuant to the Illinois
Wrongful Death Act, 740 ILCS 180, and the Illinois Survival Act, 755 ILCS 5/27-6.
II.
5.

JURISDICTION AND VENUE

The Court has jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343(a),

as Plaintiff’s claims are brought under 42 U.S.C. § 1983, the Americans with
Disabilities Act, and the Rehabilitation Act.
6.

The Court has jurisdiction over Plaintiff’s state law claims pursuant to

28 U.S.C. § 1367, as those claims are so related to the federal claims asserted in this
Complaint that Plaintiff’s state law claims form part of the same case or
controversy.

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7.

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Venue is appropriate pursuant to 28 U.S.C. § 1391(b) because one or

more of the defendants resides in the Central District of Illinois and all events
giving rise to the claims asserted in this lawsuit arose in this judicial district.
III.
8.

PARTIES

Plaintiff’s decedent is Tiffany Rusher, who at the time of her death was

a twenty-seven-year-old resident of the State of Illinois. At all times relevant
hereto, Tiffany was a pretrial detainee at the Sangamon Jail.
9.

Plaintiff Kelli Andrews (“Plaintiff”) is Tiffany Rusher’s mother and is

the administrator of Tiffany’s estate, pursuant to an order entered by the Circuit
Court for the Seventh Judicial Circuit of Illinois, Sangamon County.
10.

Wes Barr is the Sheriff of Sangamon County. In this capacity, he is

responsible for the operation of the Sangamon Jail, which is the pretrial detention
facility—i.e., the jail—of Sangamon County. This responsibility includes a duty to
safely house and to provide adequate medical care for the Sangamon Jail’s
detainees. At all times relevant to this case, Sheriff Barr acted under color of law.
He is sued in his individual and official capacities.
11.

Larry Beck is the Superintendent of the Sangamon Jail. In this

capacity, he is responsible for the day-to-day operation of the Sangamon Jail. This
includes making cell assignments and ensuring that medical and mental health
services are provided to those detainees who need such services. At all times
relevant to this case, Superintendent Beck acted under color of law. He is sued in
his individual capacity.

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12.

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Does 1-5 are sued herein by fictitious names for the reason that their

true names are unknown to Plaintiffs. Plaintiffs will seek leave to amend this
complaint to allege the true names and capacities of these Defendants when their
identities have been ascertained. Plaintiffs are informed and believe, and based
thereon allege, that these fictitiously-named defendants are responsible in some
manner for the misconduct alleged herein.
13.

Sangamon County provides for the budget of the Sangamon County

Sheriff’s Office, including the budget for the Sangamon Jail. Sangamon County is
named for indemnification purposes only, pursuant to 55 ILCS §5/5-1002.
IV.
14.

FACTS

On or about December 8, 2016, Tiffany was accused of battery while a

patient at the McFarland Mental Health Center (“McFarland”), which is located in
Springfield, Illinois. She was arrested at McFarland, and on December 15, 2016,
she was transported directly from McFarland for pretrial detention at the
Sangamon Jail.
15.

Shortly after her arrival at the Sangamon Jail, defendants Barr, Beck,

and/or Does 1-5 became aware of Tiffany’s extensive mental health history,
including her multiple prior suicide attempts.
16.

Upon Tiffany’s arrival at the Sangamon Jail, Sangamon Jail personnel

received a discharge summary that had been prepared by staff at McFarland. That
summary contained a comprehensive account of Tiffany’s history of severe mental
illness, recurrent self-harming behavior, and numerous suicide attempts. Among
other things, the Discharge Summary noted the following:

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(i)

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From October 19, 2014 to April 14, 2016, while incarcerated at the
Logan Correctional Center in Lincoln, Illinois, Tiffany made at least
ten attempts to hang herself, including by strangulation with a towel.

(ii)

During the same time period, Tiffany engaged in at least twenty-seven
instances of self-harming behavior, including cutting herself, biting
herself, banging her head against a wall, and repeatedly swallowing
inedible objects such as ink pens, toilet paper, large segments of celery
and carrot sticks, eating utensils, and toothbrushes.

(iii)

Due to Tiffany’s self-harming behavior, Logan Correctional Center
placed her on constant watch from approximately September 11, 2015
to May 3, 2016.

(iv)

On May 3, 2016, Tiffany was committed directly from Logan
Correctional Center to McFarland pursuant to a Court Order for
Involuntary Hospitalization.

(v)

Tiffany engaged in self-harming and suicidal behavior during her
hospitalization at McFarland. On multiple occasions she swallowed
large objects requiring endoscopic removal and on at least two
occasions, in June 2016 and September 2016, she attempted selfstrangulation.

(vi)

McFarland provided Tiffany with mental health treatment and
monitored her to protect her from harming herself.

(vii)

Tiffany was involved in an altercation on December 8, 2016, which led
to her battery charges and her transfer from McFarland to the

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Sangamon Jail on December 15, 2016. Upon her discharge from
McFarland, Tiffany’s diagnoses included Depression, Antisocial
Personality Disorder, and Posttraumatic Stress Disorder.
17.

On December 16, 2016, the day after her admission to the Sangamon

Jail, Sangamon Jail personnel received a phone call from a nurse at McFarland,
who explained that Tiffany had been subject to one-to-one care at McFarland and
that she had a history of attempting to asphyxiate herself.
18.

All inmates entering the Sangamon Jail are supposed to undergo a

medical screening, performed as the person enters the facility, and an examination
completed by medical staff within the first fourteen days of incarceration.
19.

Upon information and belief, Tiffany received a medical screening and

underwent a full medical examination by medical staff at Sangamon Jail within the
first fourteen days of her arrival at the jail, which provided Defendants with
additional information about Tiffany’s mental health, including her risk for suicide.
20.

On January 4, 2017 and January 17, 2017, a physician at the

Sangamon Jail assessed Tiffany as having Bipolar Disorder and Schizoaffective
Disorder, and documented that assessment in a medical progress note.
21.

On January 19, 2017, Tiffany told a nurse while in custody at the

Sangamon Jail that she was depressed.
22.

On February 20, 2017, Michael Shmikler, a social worker for Advanced

Correctional Healthcare, an entity that provides medical services to inmates in the
Sangamon Jail, treated Tiffany at the Sangamon Jail and described her as “highrisk” due to her self-harming thoughts.

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23.

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Defendant Sheriff Wes Barr is responsible for oversight of the

Sangamon County Sheriff’s Office, which includes the Sangamon Jail.
24.

Defendant Larry Beck Jr. is responsible for oversight of the day-to-day

operations of the Sangamon Jail, including but not limited to detainee cell
assignment; ensuring adequate medical and mental health services are provided to
detainees; supervising medical staff, social workers, and other personnel; and
implementing policies and procedures of the Sangamon Jail.
25.

Upon information and belief, Barr, Beck, and/or Does 1-5 knew about

Tiffany’s mental illness, her numerous prior attempts to commit suicide, and her
need for mental health treatment and constant supervision to protect her from
harm.
26.

Despite their actual knowledge of Tiffany’s need for intense mental

health treatment, defendants Barr, Beck, and/or Does 1-5 failed to arrange for
meaningful treatment for Tiffany. Instead, Defendants Barr, Beck, and/or Does 1-5
arranged for Tiffany to be placed in solitary confinement, depriving her of all
meaningful social contact with other people.
27.

While in solitary confinement, Tiffany was deprived of all property.

She was stripped naked, barred from having any undergarments or other clothing,
but for an anti-suicide blanket. She was not permitted a television or radio, books,
magazines, paper, pen or pencil, or anything else she could possibly have used to
pass her time in jail while awaiting trial. The only thing she was permitted was a
suicide blanket.

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28.

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Tiffany remained naked and alone in solitary confinement from

December 2016 through March 18, 2017.
29.

Depriving anyone of meaningful social contact for longer than a few

days is harmful to their mental health and is considered to be torture under
internationally recognized standards.
30.

Depriving a person who suffers from severe mental illness of

meaningful social contact for lengthy periods of time is toxic to their mental health.
31.

Depriving a person who is actively suicidal of all meaningful social

contact for an extended period of time is not a method of treatment recognized by
any competent medical authority. It is certain to make the person worse, not better,
increasing their risk of suicide.
32.

Upon information and belief, Tiffany was not under observation, as

required by all recognized suicide prevention protocols. Rather, upon information
and belief defendants Barr, Beck, and/or Does 1-5 had either ordered or approved
covering the observation window in Tiffany’s cell so that her actions inside the cell
could not be observed by staff.
33.

At the same time Defendants Barr, Beck, and/or Does 1-5 compounded

the risk that Tiffany would harm herself by failing adequately to prevent Tiffany
from accessing a number of items that she used to harm herself.
34.

As a direct result of the actions and failures to act of defendants Barr,

Beck, and/or Does 1-5, Tiffany further decompensated in her cell and engaged in
open and obvious self-harming and suicidal behavior consistent with her diagnosis
upon entering the Sangamon Jail. For example:

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(i)

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On January 12, 2017, Tiffany swallowed a plastic spoon and was
transferred from the Sangamon Jail to Memorial Medical Center in
Springfield, Illinois, for treatment.

(ii)

On January 19, 2017, Tiffany tried to strangle herself with a strap
from a protective medical boot worn on an injured foot.

(iii)

On January 29, 2017, Tiffany swallowed a toothbrush and was
transferred from the Sangamon Jail to Memorial Medical Center in
Springfield, Illinois, for treatment.

(iv)

On February 3, 2017, Tiffany tried to swallow a whole apple core.

(v)

On February 12, 2017, Tiffany swallowed mattress stuffing.

(vi)

On February 24, 2017, Tiffany put toilet paper up her nose and said
she could not breathe.

(vii)

On March 15, 2017, Tiffany swallowed a plastic bag.

35.

As a further direct result of the actions and failures to act of

Defendants Barr, Beck, and/or Does 1-5, on March 18, 2017, Tiffany was deprived of
oxygen to her brain for a lengthy period of time sufficient to cause irreparable
damage to her brain. An autopsy later conducted by the Sangamon County Coroner
noted that Tiffany “was found unresponsive in her cell, with a strip of hand towel
wrapped tightly around her neck.”
36.

On March 18, 2017, Tiffany was transferred from Sangamon Jail to St.

John’s Hospital in Springfield, Illinois and was placed on life support.
37.

On March 30, 2017, Tiffany died as a result of the injuries she had

sustained while in Defendants’ custody. An autopsy conducted by the Sangamon

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County Coroner concluded that Tiffany’s death was caused by self-inflicted and
deliberate ligature strangulation.
Count I: Fourteenth Amendment
Against: Barr (official capacity)
38.

Each paragraph of this complaint is incorporated as if fully restated

39.

Tiffany was confined under conditions that posed a substantial risk of

here.

serious harm to her health and safety, in that she was held in isolation, deprived of
all meaningful social contact, deprived of all personal property, and left naked in a
bare cell but for a suicide blanket for over three months.
40.

Defendant Barr was deliberately indifferent to Tiffany’s health and

safety.
41.

Defendants Barr failed to establish a system for providing necessary

mental health care to severely mentally ill detainees like Tiffany.
42.

Defendants Barr failed to establish a system for providing humane,

non-damaging detention to severely mentally ill detainees like Tiffany.
43.

Defendant Barr failed to establish policies and procedures sufficient to

protect severely suicidal detainees like Tiffany from self-harm.
44.

Defendant Barr failed to establish policies and procedures to ensure

that suicidal detainees like Tiffany were properly observed and kept safe.
45.

Defendant Barr failed to establish policies and procedures to ensure

the safety of detainees like Tiffany.

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46.

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Defendant Barr’s actions and inactions caused harm to Tiffany,

including severe emotional distress during the time she was confined to the jail, and
ultimately her death.
COUNT II: Fourteenth Amendment
Against: Barr (individual capacity), Beck (individual capacity) and Does 1-5
47.

Each paragraph of this complaint is incorporated as if fully restated

48.

Tiffany suffered from multiple, severe mental illnesses and had an

here.

extensive history of engaging in self-harming and suicidal behaviors, which
included repeated attempts to hang herself and swallow inedible objects.
49.

Defendants knew about Tiffany’s history of mental illness, prior

suicide attempts, and self-harming tendencies at Logan Correctional Center and at
McFarland.
50.

Defendants similarly knew about Tiffany’s suicidal behavior and

thoughts, self-inflicted injuries, and ongoing mental illness that existed while
Tiffany was in Defendants’ custody at the Sangamon Jail, such that any and all risk
of Tiffany committing suicide was known and foreseeable.
51.

Defendants were deliberately indifferent to Tiffany’s medical needs

and her risk of suicide by failing to provide Tiffany with adequate medical
treatment and failing to take appropriate precautions to protect Tiffany from selfharm.
52.

Defendants’ failure to provide adequate medical treatment, including

but not limited to a lack of constant supervision and insufficient mental health care,
constituted a clear disregard of the risk to Tiffany’s life.
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53.

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Defendants’ placement of Tiffany in solitary was also harmful in and of

itself, in that it caused her to suffer severe mental anguish during her detention at
Sangamon Jail.
54.

Defendants’ deliberate indifference to Tiffany’s medical needs and her

risk of suicide violated Tiffany’s rights as secured by the Fourteenth Amendment.
As a direct and proximate result of Defendants’ deliberate indifference, Tiffany
suffered mental anguish while she was detained at the Sangamon Jail, and she
asphyxiated herself with a towel on March 18, 2017, and died on March 30, 2017.
COUNT III: Americans with Disabilities Act
Against: Barr (official capacity)
55.

Each paragraph of this complaint is incorporated as if fully restated

56.

Congress enacted the ADA “to provide a clear and comprehensive

here.

national mandate for the elimination of discrimination against individuals with
disabilities.” 42 U.S.C. § 12101(b)(1). Title II of the ADA states that “no qualified
individual with a disability shall, by reason of such disability, be excluded from
participation in or be denied the benefits of services, programs, or activities of a
public entity, or be subjected to discrimination by any such entity.” 42 U.S.C. §
12132.
57.

To prevent discrimination, 28 C.F.R. § 35.130(b)(7) requires a public

entity to “make reasonable modifications in policies, practices, or procedures when
the modifications are necessary to avoid discrimination on the basis of disability,
unless the public entity can demonstrate that making the modifications would
fundamentally alter the nature of the services, program, or activity.”
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58.

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The Sangamon County Sheriff’s Office is a public entity as defined in

42 U.S.C. § 12131(1).
59.

At all times relevant to this Complaint, in light of her severe mental

illness, Tiffany was a qualified individual with a disability within the meaning of
Title II of the ADA, 42 U.S.C. § 12131(2), and had a right not to be subjected to
discrimination on the basis of her disability by Defendant.
60.

Due to her mental illnesses, Tiffany frequently contemplated and

engaged in suicidal behavior and could not take adequate care of herself.
61.

As a detainee at the Sangamon Jail, Tiffany was wholly dependent

upon Sheriff Barr for basic daily needs and appropriate accommodations, including
mental health care and accommodation. Individuals in the custody of defendant are
also dependent on the defendant for all of their basic daily needs, including food,
exercise, and safety.
62.

Under the Title II of the ADA and 28 C.F.R. § 35.130(a), Sheriff Barr is

responsible for ensuring that individuals in his custody with known disabilities are
provided with reasonable accommodations to prevent discrimination on the basis of
disability and are not, on the basis of disability, excluded from participation in or
denied the benefits of services, programs, or activities because of their disability.
63.

Despite Tiffany’s known and obvious disability Sheriff Barr failed to

reasonably accommodate Tiffany’s disability by failing to provide her with
reasonably suicide-proof and humane conditions of confinement.
64.

The failure of the Sheriff’s Office to provide adequate mental health

treatment to Tiffany failed to accommodate Tiffany’s disability.

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65.

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The isolation of Tiffany without any meaningful social contact and

without any personal property constituted discrimination against Tiffany as a
result of her disability.
66.

As a result of the wrongful conduct of the Sheriff’s Office, Tiffany’s

mental health condition was greatly exacerbated, and she was subjected to
unnecessary pain and suffering, and she died.
COUNT IV: Rehabilitation Act
Against: Barr (official capacity)
67.

Each paragraph of this complaint is incorporated as if fully restated

68.

The purpose of the Rehabilitation Act is to ensure that no “qualified

here.

individual with a disability in the United States . . . shall, solely by reason of [ ]
disability, be excluded from the participation in, be denied the benefits of, or be
subjected to discrimination under any program or activity receiving Federal
financial assistance . . . .” 29 U.S.C. § 794(a).
69.

Tiffany was, at all times relevant to this complaint, a qualified

individual with a disability within the meaning of the Rehabilitation Act, 29 U.S.C.
§ 705(2), and has a right not to be subjected to discrimination on the basis of her
disability. 29 U.S.C. § 794(a).
70.

The Sangamon County Sheriff’s Office receives Federal financial

assistance within the meaning of 29 U.S.C. § 794(a).
71.

The Sheriff’s Office constitutes “program[s] or activit[ies]” within the

meaning of 29 U.S.C. § 794(b)(1)(A)-(B) and/or (b)(2)(B) and was required to comply
with the Rehabilitation Act.
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72.

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The failure of the Sheriff’s Office to provide adequate mental health

treatment to Tiffany failed to accommodate Tiffany’s disability.
73.

The isolation of Tiffany without any meaningful social contact and

without any personal property constituted discrimination against Tiffany as a
result of her disability.
74.

As a result of the wrongful conduct of the Sheriff’s Office, Tiffany’s

mental health condition was greatly exacerbated, and she was subjected to
unnecessary pain, suffering, and death.
COUNT V: Wrongful Death (740 ILCS 180)
Against: All defendants
75.

Each paragraph of this complaint is incorporated as if fully restated

76.

Defendants had a duty to protect Tiffany from harm when such harm

here.

was reasonably foreseeable.
77.

Defendants breached that duty.

78.

As a result of defendants’ breach of that duty, Tiffany died.

79.

Tiffany’s next of kin have suffered damages from the loss of Tiffany,

including grief, sorrow, mental suffering, and loss of society.
COUNT VI: Survival Act and Funeral Expenses
Against: All defendants
80.

Each paragraph of this complaint is incorporated as if fully restated

here.

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81.

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Count VI is alleged against Defendants in their individual capacities

and brought by Plaintiff as Tiffany’s personal representative in her capacity as
administrator of Tiffany’s estate.
82.

This count is brought pursuant to the Survival Act, 755 ILCS 5/27-6,

for the medical, funeral and burial expenses and the pain and suffering experienced
by Tiffany prior to her death.
83.

As a result of one or more of the willful and wonton acts or omissions

described in the previous paragraphs, Tiffany experienced suicidal thoughts, decline
in mental health, agitation, mental abuse, punishment, pain and suffering, and
other injuries including medical expenses prior to her death.
84.

As a direct and proximate result of the death of Tiffany, the estate

incurred funeral and burial expenses.
COUNT VII: Respondeat Superior
Against: Barr
85.

Each paragraph of this complaint is incorporated as if fully restated

86.

Sheriff Wes Barr employed various Sangamon Jail personnel and staff

here.

who provided inadequate care to Tiffany and/or insufficiently monitored Tiffany
while working in the course and scope of their employment.
87.

Sheriff Wes Barr, by and through his employees, is liable for all

Defendants’ aforementioned unlawful acts that were the direct and proximate cause
of Tiffany’s injuries, and her death on March 30, 2017.
COUNT VIII: Indemnification
Against: Sangamon County

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88.

Each paragraph of this complaint is incorporated as if fully restated

89.

Illinois law provides that public entities are directed to pay any tort

here.

judgments for compensatory damages for which employees are liable within the
scope of their employment activities.
90.

Defendants Barr, Beck, and Does 1-5 were employees and agents of

Defendants Sangamon County and/or the Office of the Sheriff of Sangamon County
and acting within the scope of their employment in committing the misconduct
described herein.
91.

Sangamon County is obligated by Illinois law to pay any judgment

relating to the operation of the Sangamon Jail entered against the Sangamon
County Sheriff’s Office, Barr, Beck, and Does 1-5.
V.

RELIEF REQUESTED

WHEREFORE, Plaintiff respectfully requests judgment against Defendants,
jointly and severally, for the following:
A.

An award of compensatory, punitive, and nominal damages;

B.

An award of full costs and attorneys’ fees arising out of this
litigation pursuant to 42 U.S.C. § 1988, the Americans with
Disabilities Act, and the Rehabilitation Act, and;

C.

Any and other further relief this Court may deem just and
appropriate.
VI.

DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff
hereby demands a trial by jury in this action of all issues so triable.

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Dated: March 11, 2018

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Respectfully submitted,
s/ Alan Mills
.
Alan Mills - alan@uplcchicago.org
Nicole Schult - nicole@uplcchicago.org
Uptown People’s Law Center
4413 North Sheridan Rd.
Chicago, Illinois 60640
Tel: (773) 769-1411
Fax: (773) 769-2224
/s/ Emmanuel Andre

.

Emmanuel Andre - eandre@northsidetlc.com
Northside Transformative Law Center
1543 W. Morse Ave.
Chicago, IL 60626
(312) 219-654
/s/ Stephen H. Weil

.

Stephen H. Weil – steve@weilchardon.com
Alexis G. Chardon – ali@weilchardon.com
Weil & Chardon LLC
333 S. Wabash Ave., Suite 2700
Chicago, IL 60604
312-585-7404
Attorneys for Plaintiff

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