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Menard Correctional Center in downstate Chester, Illinois, Aug. 31, 2012. (E. Jason Wambsgans/Chicago Tribune)
Menard Correctional Center in downstate Chester, Illinois, Aug. 31, 2012. (E. Jason Wambsgans/Chicago Tribune)
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The Illinois Department of Corrections confined inmates in “dungeon-like conditions” in solitary confinement and refused to allow them to exercise, causing chronic physical and psychological pain, a complaint filed on Monday alleges.

The amended complaint, filed in federal court in Southern Illinois, names IDOC Director Latoya Hughes, along with other wardens and officials, accusing them of depriving some inmates at Menard Correctional Center of nearly all ability to move their bodies on a daily basis.

Inmates also were held in excessively long, dirty and restrictive periods of solitary confinement, the newly-filed complaint said, adding to a long history of scrutiny of the state prison system’s practices around holding prisoners in isolated conditions.

“The ability to exercise is a constitutionally protected basic human need, just like food, water, and warmth,” the complaint says. “And just like food, water and warmth, exercise is not a luxury or privilege that must be earned, or that can be withheld from an incarcerated person. Yet, that is exactly what has been systematically perpetrated.”

IDOC officials did not immediately respond to a request for comment.

The lawsuit is filed by three IDOC inmates, Omar Johnson, Clarence Jones, and Alexander Castillo, all of whom have been held for extended periods of time in solitary confinement at Menard, a maximum-security male prison, the suit alleges. The amended complaint was filed by the MacArthur Justice Center and the law firm Akin after Johnson, in March, filed an initial, handwritten, pro se version.

The lawsuit maintains that withholding exercise from inmates amounts to a cruel and unusual punishment in violation of prisoners’ constitutional rights.

At Menard, the plaintiffs were confined to cells in which they could “not fully extend their arms, and that are far too cramped to allow for meaningful body movement, much less exercise.” For months, or even a year at a time, the plaintiffs were denied “yard time,” meaning they had no fresh air or opportunity to stretch their legs.

In their cells, plaintiffs “cannot even do a push-up or jumping jack without bumping into the bunk or the wall,” the complaint said.

Further, the complaint alleges, inmates in the solitary confinement cells are forced to live in squalor, subject to unventilated dirty cells with black mold, sweltering in the summer and freezing in the winter.

IDOC officials engage in the process of “stacking” consecutive punishments of solitary confinement, in some cases stripping them of yard access, the complaint says.

Jones was held in solitary confinement for 356 consecutive days, during which he was denied yard access, the complaint says. His muscles atrophied, and he developed chronic neck and back pain, it alleges.

Jones has had no history of violence at Menard, the complaint says, but he was given a disciplinary ticket and sentenced to a year of segregation for having a tattoo needle in his cell.

“The denial of exercise to the Plaintiffs was not due to any imminent concern for the safety or security of others,” the complain said. “There was no justification for the long-term denial of exercise, movement, and out-of-cell time each of the Plaintiffs endured.”