Electronic Detention Program-Sex Offender

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7^th Circuit Court of Appeals

Case Name: BenYehudah Whitfield, II v. Jeannette Cowan

Case No.: 20-1747

Officials: Wood, Brennan, and Scudder, Circuit Judges.

Focus: Electronic Detention Program-Sex Offender

Whitfield was poised to be released from Menard Correctional Center in January 2010, commencing a period of mandatory supervised release. However, on that particular day, the prison authorities provided Whitfield with only the signature page of a document known as the “Electronic Detention Program Agreement.” This page explicitly stated that the stipulated conditions of the program solely applied to cases involving sex offenders. Whitfield, who was not classified as a sex offender, expressed his reservations about signing the agreement without a clear explanation from a prison official elucidating why he, as a non-sex offender, was required to sign a document designed exclusively for individuals convicted of sex offenses. Despite Whitfield’s objections, his concerns were dismissed.

Clinical services supervisor Spiller instructed Whitfield on four occasions to sign the agreement. Yet, due to his steadfast refusal, she eventually issued him a disciplinary ticket for failing to comply with a direct order. Consequently, Whitfield was transferred to a state of disciplinary segregation. In the aftermath, the Illinois Prisoner Review Board convened a hearing and determined that Whitfield had breached the terms of his supervised release, leading to the revocation of his eligibility for supervised release. Consequently, Whitfield’s period of confinement was extended by another 18 months.

Subsequently, Whitfield initiated a lawsuit against Spiller, along with other officials from Menard and members of the Board, asserting violations of his constitutional rights under 42 U.S.C. 1983. Over time, the scope of the case narrowed down to Whitfield’s claims against Spiller and the former warden, Gaetz, focusing on alleged infringements of his rights protected by the First and Eighth Amendments. In review, the Seventh Circuit determined that while the district court rightfully granted summary judgment to the defendants on certain claims, there existed sufficient evidence to indicate that Spiller’s actions had indeed violated Whitfield’s rights under the First Amendment.

Affirmed in part and reversed in part

Decided 08/07/23

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