The answers to some of our questions are in this filing. Below are excerpts from the document.
04/11/2024 | Memorandum/Brief Filed
Memorandum of Law in Support of Defendant Allen's Motion to Suppress
Filed By: Allen, Richard M. |
drive.google.com
(excerpts)
Prison records reflect that Allen was placed on "suicide watch" during the majority of his stay at the WCU, including upon his initial detention in November of 2022. (see attached Adult Mental Health Order of 11/3/22).
This occurred despite the fact there were no underlying findings to suggest he was suicidal.
***
Allen had also battled depression throughout most of his adult life. He was medicated
over the course of his life and in fact, had sought out therapeutic resources to treat and manage
his depression. (see pp. 45 of INE).
5 The IDOC gave very little consideration to Allen's
condition at the time of his intake and initial incarceration in the WCU, especially given the
unusual circumstances in which he was detained. It is also believed that Allen's medications were administered in less than consistent fashion while he was on the unit, all of which would
have contributed to his inability to endure his living environment during his pre-trial detention at
the WCU.
(Footnote)
5. Independent Neuropsychological Evaluation dated 3/31/24 offered up to the court in appendix form.
***
Allen's attorneys have conducted depositions, watched video from Allen's cell and other
video from within the prison, reviewed prison records regarding Allen's detention, reviewed
Allen's medical and psychiatric records, and listened to audio interviews of prison inmates and
guards conducted by law enforcement 'officials. Through this process, Allen's attorneys have
learned that Allen has been accused of making incriminating statements to both inmates and
guards.
Nearly all of these statements appear to have occurred between mid-March of 2023 and
June of 2023. During this time frame, there also exists medical/psychiatric records suggesting
that Allen was in state of psychosis. (See attached Report of Treatment Review Committee
RC) Hearing).
***
All of this occurred while Allen's medications were being adjusted by the prison medical
team, the combination of which factors reduced him to nothing more than human experiment.
Allen's free will was overcome.