Armato v. Grounds, No. 13-1995 (7th Cir. 2014)Annotate this Case
Because of inaccurate information about time served in the county jail for two theft convictions, Armanto’s release date was recalculated. After receiving orders from the court that entered his convictions and concerned about the conditions for releasing Armanto, who was previously convicted as a sex offender, employees of the Illinois Department of Corrections (IDOC) sought advice from the Office of the Attorney General. Because the court had not imposed mandatory supervision, IDOC “violated him at the door,” so that he was not released as he expected. After his release, Armato sued five IDOC employees, claiming violation of Armato’s constitutional rights in violation of 42 U.S.C. 1983 and false imprisonment.. The district court granted defendants summary judgment, finding that no rational trier of fact could find that Armato was unlawfully detained beyond his court-ordered release date. The Seventh Circuit affirmed. Armato did not suffer any injury because he was released prior to the precise date in an “Agreed Order,” the defendants were not deliberately indifferent to Armato’s incarceration, but diligently pursued relief from the AG’s Office for clarification, and Armato’s due process claims failed as a matter of law and were precluded by the remedies available to him in state court.