Opinion

Love

Court: District Court, S.D. Illinois
Filed: Aug 6, 2026
Cited by: 0 cases
Authority: More cited than 44.1%

The opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF ILLINOIS

ABDUL LOVE,

Plaintiff,

v. Case No. 3:22-CV-2340-NJR

LATOYA HUGHES,

Defendant.

MEMORANDUM AND ORDER

ROSENSTENGEL, District Judge:

Pending before the Court is a motion for reconsideration (Doc. 100) filed by pro se

Plaintiff Abdul Love, an inmate incarcerated at Pinckneyville Correctional Center within

the Illinois Department of Corrections (IDOC). On July 27, 2026, the Court granted

summary judgment against Love on one of his two claims after determining Love had

failed to submit sufficient evidence to establish that former defendant Richard Arnold

had been personally involved in an alleged deprivation of his First Amendment right to

free exercise. (Doc. 96, at 5–9).1 Love now asks this Court to reconsider that decision. For

the reasons set forth below, the motion is denied.

BACKGROUND2

Love is a practicing Muslim who participates in Ramadan, a month-long religious

celebration that requires worshipers to fast between the hours of sunrise and sunset.

1 See also Love v. Hughes, No. 22-cv-2340, 2026 WL 214913 (S.D. Ill. July 27, 2026).

2 The following facts are taken from this Court’s order partially granting summary judgment unless

otherwise noted. (Doc. 96, at 2–4).

At sunset, they must break their fast, ideally with dates and water.

In 2022, Pinckneyville Correctional Center was under an administrative

quarantine, which meant that meals were brought to inmates’ cells. Love, a Pinckneyville

inmate, was supposed to receive his dinner tray around sunset. Dietary staff brought the

Ramadan trays to the cell house around 45 minutes before sunset. But the trays were not

delivered to the inmates in their cells until 30 minutes to two hours after sunset. As a

result, Love had to break his fast with his own personal food, which he purchased from

the commissary.

At all relevant times, Arnold was the facility chaplain at Pinckneyville. As

Chaplain, Arnold was required to coordinate with the prison administration to facilitate

the observance of Ramadan. However, he did not deliver the dinner trays to participants.

The trays were delivered and passed out by dietary supervisors and inmates serving as

porters.

Love formally complained, but the delays continued. Love felt Arnold had done

nothing to address his concerns. He sued Arnold and others for various alleged

violations; in particular, he claimed that Arnold had violated his free exercise rights

under the First Amendment and sought damages under 42 U.S.C. § 1983 (See Doc. 96,

at 4–9). The Court granted summary judgment against Love on this claim, finding he had

not submitted enough evidence for a jury to decide that Arnold was personally involved

in the alleged deprivation of his rights. Id. Specifically, Love had not shown that Arnold

had the power to require the dietary staff to deliver dinner trays earlier. Id.

LEGAL STANDARD

Motions to reconsider interlocutory orders (i.e., orders entered before final

judgment) are left to the discretion of the trial court. E.g., Akzo Coatings, Inc. v. Aigner

Corp., 909 F. Supp. 1154, 1159–60 (N.D. Ind. 1995) (citations omitted); see also FED. R. CIV.

P. 54(b) (“[A]ny order or other decision, however designated, that adjudicates fewer than

all the claims . . . does not end the action as to any of the claims or parties and may be

revised at any time before the entry of a judgment adjudicating all the claims . . . .”).

“Reconsideration is not an appropriate forum for rehashing previously rejected

arguments or arguing matters that could have been heard during the pendency of the

previous motion.” Caisse Nationale de Credit Agricole v. CBI Indus., Inc., 90 F.3d 1264, 1270

(7th Cir. 1996) (citations omitted). Instead, “[a] motion for reconsideration ‘essentially

enables a district court to correct its own errors, sparing the parties and the appellate

courts the burden of unnecessary appellate proceedings.’” Brown v. Auto-Owners Ins. Co.,

No. 24-cv-04131, 2026 WL 2210111, at *2 (C.D. Ill. 2026) (quoting Ressell v. Delco Remy Div.

of Gen. Motors Corp., 51 F.3d 746, 749 (7th Cir. 1995)).

DISCUSSION

Love argues this Court erred when it determined that he had not submitted

sufficient evidence to establish Arnold’s personal responsibility for the alleged

constitutional violation (Doc. 100, at 2–5), a requirement for liability under § 1983.

E.g., Vance v. Peters, 97 F.3d 987, 992 (7th Cir. 1996). He claims he did submit such

evidence: specifically, he argues that he “has presented documentation proving that

Defendant Arnold had the authority to direct both dietary and security staff to provide

[him] with his Ramadan dinner tray prior to sunset, thereby creating an issue of material

fact.” (Doc. 100, at 2–3). Love points to an IDOC Administrative Directive which states

that “Facility Chaplains shall . . . coordinate the administration of religious rites, where

appropriate.” Id. at 3, 10. He also invokes Arnold’s admission in the summary judgment

briefing that he was “required to coordinate with the [prison] [a]dministration regarding

the religious rites associated with the Islamic practices observed during the month of

Ramadan.” (Doc. 90, at 1–2; see Doc. 100, at 3). He claims this evidence “establish[es] that

Defendant Arnold had lawful authority under [the laws of Illinois] to direct the . . .

dietary supervisors and security staff to serve Plaintiff his Ramadan dinner trays prior to

sunset.” (Doc. 100).

Unfortunately for Love, his evidence does not carry his burden. All it establishes

is that Arnold was required to “coordinate” with the other staff at Pinckneyville

regarding the administration of Ramadan—not that Arnold had the authority to order

dietary staff (or anyone else) to deliver dinner trays at any particular time (a necessary

pre-requisite for his personal involvement, as this Court explained in its prior order).

Additionally, Arnold and Love each submitted evidence confirming that the delivery of

the dinner trays was not within Arnold’s authority to manage; instead, all evidence in the

record confirms that tray delivery was managed by dietary and cell house staff. (Doc. 81-

2, at 2 (evidence submitted by Defendants); Doc. 90, at 37 (evidence submitted by Love);