The opinion
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
NISSAN SJ BLAKES )
)
Plaintiff, )
)
vs. ) Civil No. 3:26-cv-00026-GCS
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SGT. CRAWFORD, LT. LIVINGSTON, )
)
Defendants. )
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MEMORANDUM & ORDER
SISON, Magistrate Judge:
This matter is before the Court on Plaintiff Nissan SJ Blake’s Motion for
Preliminary Injunction (Doc. 29) and a related letter submitted to the Court (Doc. 35).
Plaintiff is an inmate in the Illinois Department of Corrections (“IDOC”), currently
incarcerated at Lawrence Correctional Center. This case arises out of an incident during
which Defendants Livingston and Crawford allegedly used excessive force against
Plaintiff after he threw juice on Defendant Crawford. (Doc. 1, p. 5; Doc. 19, p. 7). Plaintiff
alleges that various individuals, including Defendants Crawford and Livingston, have
retaliated against him for filing the instant lawsuit. (Doc. 29, p. 2; Doc. 35, p. 1). Plaintiff
seeks a transfer to a different prison. (Doc. 29, p. 3). Defendants Crawford and Livingston
oppose the motion (Doc. 32). For the following reasons, the Court DENIES Plaintiff’s
motion.
LEGAL STANDARDS
The purpose of a preliminary injunction is to preserve the positions of the parties
until a trial on the merits of a case can be held. To obtain a preliminary injunction, a
plaintiff must demonstrate that (1) his underlying case has some likelihood of success on
the merits; (2) no adequate remedy at law exists; and (3) he will suffer irreparable harm
without the relief. See Mays v. Dart, 974 F.3d 810, 818 (7th Cir. 2020) (citing Speech First,
Inc. v. Killeen, 968 F.3d 628, 637 (7th Cir. 2020)). If these elements are established, the
Court must then balance the potential harm to the movant if the preliminary injunction
were denied against the potential harm to the non-movant if the injunction were granted.
See Mays, 974 F.3d at 810; Courthouse News Service v. Brown, 908 F.3d 1063, 1068 (7th Cir.
2018). The Court must also consider whether granting the preliminary injunction is in
the public interest. See Courthouse News Service, 908 F.3d at 1068. The Prison Litigation
Reform Act (“PLRA”) limits the scope of preliminary injunctive relief that courts may
provide. Specifically, the PLRA provides that “[p]reliminary injunctive relief must be
narrowly drawn, extend no further than necessary to correct the harm the court finds
requires preliminary relief, and be the least intrusive means necessary to correct that
harm.” 18 U.S.C. § 3626(a)(2).
Injunctive relief is appropriate if it addresses a matter presented in the underlying
suit and seeks relief of the same character sought in the underlying action. See, e.g., Devose
v. Herrington, 42 F.3d 470, 471 (8th Cir. 1994) (stating that “a party moving for a
preliminary injunction must necessarily establish a relationship between the injury
claimed in the party’s motion and the conduct asserted in the complaint.”); Daniels v.
Dumsdorff, Case No. 19-cv-00394-NJR, 2019 WL 3322344, at *1 (S.D. IIL. July 24, 2019).
DISCUSSION
Plaintiff has not established a relationship between the injury alleged in his motion
and the conduct asserted in the complaint. The Court’s screening order permitted
Plaintiff to proceed on one count of excessive force against Defendants Livingston and
Crawford.! (Doc. 19, p. 7). Plaintiff's motion describes many instances of conduct that
Plaintiff claims are retaliation for filing this lawsuit. But even if that is the case, the
allegations do not relate to the harm that Plaintiff suffered from Defendants Livingston’s
and Crawford’s alleged use of excessive force. Thus, injunctive relief is not appropriate.
If Plaintiff wishes to pursue the claims alleged in his motion and letter, he may do
so by filing a separate case, subject to the rules and requirements of Section 1983 and the
PLRA. See Daniels, 2019 WL 3322344, at *1. The Court expresses no opinion on the merits
of any such claims.
CONCLUSION
For the reasons explained above, the Court DENIES Plaintiff's Motion for
Preliminary Injunctive Relief.
IT IS SO ORDERED.
DATED: August 7, 2026. Gilbert C Dial) signed by Gilbert sison
Sison yo
GILBERTC.SISON
United States Magistrate Judge
1 Plaintiff's other claims were dismissed, but even if they were not, they do not relate
to matters raised in Plaintiff's injunction. (Doc. 19).
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