Justia Civil Rights Opinion Summaries

McCann was severely burned while attempting to commit arson at his mother’s house and spent three weeks in the hospital before being released to police custody. McCann died from a doctor’s over-prescription of methadone while detained and awaiting trial at the Ogle County Correctional Center. His estate brought suit under 42 U.S.C. 1983, alleging deliberate indifference to McCann’s severe burn wounds and related medical needs. The treating physician and his private employer settled the claims. The district court entered summary judgment for the remaining defendants, concluding that the evidence did not show that any individual defendant acted with deliberate indifference. The Seventh Circuit subsequently replaced deliberate indifference with a standard requiring a showing of objective reasonableness for a claim challenging the medical care provided to a pretrial detainee like McCann. Measuring the record evidence under this new standard, the Seventh Circuit affirmed the award of summary judgment to the individual defendants and a determination that the record evidence did not support a claim for municipal liability against Ogle County under Monell. View "McCann v. Ogle County" on Justia Law

Since entering the custody of the Wisconsin Department of Corrections in 2009, Wilson has sought medical treatment for dementia and Alzheimer’s disease, neck and throat pain, and difficulty breathing and swallowing. He alleged that Oshkosh Correctional Institution's doctors were deliberately indifferent in their treatment of these ailments in violation of his Eighth Amendment rights. The district court found that no reasonable jury could find that the doctors were deliberately indifferent. The Seventh Circuit affirmed summary judgment in favor of the defendants. Wilson failed to prove that he actually suffers from Alzheimer’s disease or dementia. None of the testing done at Oshkosh or at the Wisconsin Resource Center provided any evidence that Wilson suffered from a cognitive disorder. These disorders are difficult to identify and diagnose, but without such evidence, Wilson cannot show that he suffered a serious medical condition, let alone indifference in the treatment of that condition. The doctor did investigate Wilson’s mental health condition, referring him to a psychiatrist and a specialty center for extensive observation. The record is replete with evidence of the doctor’s attempts to diagnose the source of Wilson’s pain. He worked with endocrinologists, an otolaryngologist, a speech pathologist, a pulmonologist, a neurosurgeon, and a dentist. View "Wilson v. Adams" on Justia Law

Rhinehart, then a prisoner, filed suit under 42 U.S.C. 1983, alleging that medical providers associated with the Michigan Department of Corrections (MDOC) denied him necessary treatment for his end-stage liver disease (ESLD). When he died, his brothers filed an amended complaint on behalf of his estate. The district court granted two doctors summary judgment on their Eighth Amendment claims. The Sixth Circuit affirmed. To establish a prison official’s deliberate indifference to a serious medical need, an inmate must show that the alleged wrongdoing was objectively harmful enough to establish a constitutional violation and that the official acted with a culpable enough state of mind, rising above gross negligence. The Rhineharts failed to establish those elements. View "Rhinehart v. Scutt" on Justia Law

Proctor, an Illinois prisoner who was confined for seven years at Hill Correctional Center, suffers from chronic abdominal pain and spasms in his colon. He sued medical providers working at Hill for Wexford Health Sources, the contractor providing healthcare to Illinois prisoners, and corrections officials, claiming that they violated the Eighth Amendment by not ordering a colonoscopy and endoscopy to diagnose his persistent abdominal pain. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed. A jury could not reasonably find that the defendants were deliberately indifferent to Proctor’s medical condition. Proctor’s abdominal pain and colon spasms were investigated thoroughly, and that investigation substantiated only a diagnosis of IBS. Over the course of treating him, the medical professionals routinely performed physical exams and ordered X‐rays, an ultrasound, bloodwork, stool cultures, and other tests, but the results were consistently normal. The decision whether further diagnostic testing— like a colonoscopy—was necessary is “a classic example of a matter for medical judgment. View "Proctor v. Sood" on Justia Law

Inmate’s allegation that prison dentist intentionally sutured inmate’s gum without removing pieces of broken drill bit was sufficient to withstand screening. While Dr. Craig was extracting a wisdom tooth from Echols, an Illinois inmate, a drill bit broke. Craig sutured Echols’ gum with gauze and at least one half‐inch long piece of the broken bit still inside, where it caused pain for about two weeks before it was finally removed. Echols alleges that Craig sutured the site after intentionally packing it with non‐soluble gauze and without first locating the missing shards from the broken drill bit. The district court screened Echols’ 42 U.S.C. 1983 complaint under 28 U.S.C. 1915A, and dismissed it, stating that Echols’ allegations were factually frivolous. The Seventh Circuit vacated, holding that Echols’ allegations are quite plausible and state a claim for violation of the Eighth Amendment. Echols sufficiently alleged that Craig’s actions were so inappropriate that the lawsuit cannot be dismissed at screening. View "Echols v. Craig" on Justia Law

The Seventh Circuit reversed summary judgment for the defendants in a suit by Johnson, an inmate of the Rushville Treatment and Detention Facility for persons believed prone to sexual violence, claiming that staff had caused Johnson to take the antipsychotic drug Risperdal, for more than a month, without Johnson’s knowledge or consent. The staff did not follow Illinois’s procedures for ordering forced medication; Johnson had not been found to be dangerous to himself or others. The doctor prescribed Risperdal after Johnson complained about feelings of aggression and hopelessness, even though Johnson refused to consent. The doctor stated that he wrote the prescription so that Johnson could take the medication if he wanted it. The nurse, not knowing what the pill was, included the Risperdal with Johnson’s medications for blood pressure, cholesterol, and stomach problems, so Johnson took the drug without noticing it. The Seventh Circuit noted that the Supreme Court has recognized a “significant liberty interest,” under the due process clause in “avoiding the unwanted administration of antipsychotic drugs,” which can have “serious, even fatal, side effects.” While Johnson was not forced to take the pill, the doctor “must have known that pills were delivered to the inmates, unlabeled, in little cups.” View "Johnson v. Tinwalla" on Justia Law

Collins, a regular heavy drinker, had suffered alcohol withdrawal, and kept a bottle of Librium to treat withdrawal and anxiety. Collins had Librium with him when he was arrested for DUI. The jail physician, Dr. Al‐Shami, who approved Collins’s use of the Librium while in custody. Collins was taken to a cell; officers checked on him every 15 minutes. The next day Collins began to complain of shaking from alcohol withdrawal. He was given Librium and vitamins. By lunchtime, Collins was better and eating normally. In the afternoon, he began to complain again. A nurse called Dr. Al‐Shami, who ordered that Collins be given the normal treatment for alcohol withdrawal. After being treated for additional incidents, Collins was taken to the hospital. The examining physician concluded that Collins was not suffering from delirium tremens. Collins was returned to the jail. Collins continued to display strange behavior, interspersed with periods of normalcy. Officers continued to check on Collins every 15 minutes. Eventually, Collins was again taken to the hospital. Collins was hypothermic, had low blood pressure, and was suffering from dehydration, sepsis, and acute respiratory failure. He was in a medically‐induced coma for several days. The Seventh Circuit affirmed summary judgment for the defendants in Collins's suit under 42 U.S.C. 1983, concluding that the level of care was reasonable. View "Collins v. Al-Shami" on Justia Law

While lifting a heavy door at his prison job in 2008, Cesal heard a “snap” in his back and felt pain in his leg and hip. He sought treatment from the prison’s medical staff but was dissatisfied with their response. He alleged that he received a three-year runaround, during which his pain was ignored, that the Clinical Director canceled Cesal’s insulin prescription in retaliation for Cesal’s filing a complaint about the inadequate care. Without the prescription, Cesal, an insulin-dependent diabetic, was unable to control his blood sugar and suffered additional pain and harm. He filed a second complaint with the prison about the insulin deprivation. Cesal, acting pro se, sued the Clinical Director and another Pekin physician. At the screening phase, 28 U.S.C. 1915A, the district court identified an Eighth Amendment deliberate indifference claim and a First Amendment retaliation claim related to the withholding of insulin. The court granted the defendants summary judgment, reasoning that the statute of limitations had run and that, in any event, there was no question of material fact that would justify allowing his case to proceed. The Seventh Circuit affirmed, acknowledging that "Cesal’s allegations are troublesome," but noting important differences between ordinary, or even aggravated, medical malpractice, and an Eighth Amendment violation View "Cesal v. Molina" on Justia Law

Appellant Sean Wright, a former inmate of the Alaska Department of Corrections (DOC) who was incarcerated at an out-of-state correctional facility under contract with DOC, filed a medical malpractice and 42 U.S.C. 1983 civil rights action against officials employed by the out-of-state correctional facility and by DOC. The civil rights claims alleged that the corrections officials were deliberately indifferent to Wright's medical needs. The superior court granted summary judgment dismissing the medical malpractice action as barred by the two-year statute of limitations. Subsequently the court granted summary judgment on the deliberate indifference claims against the inmate. In the course of the proceedings, Wright unsuccessfully sought to have the superior court judge removed for alleged bias. Wright appealed these decisions. Finding no reversible error, the Supreme Court affirmed. View "Wright v. Anding" on Justia Law

Inmate Diggs injured his knee in a fight in 2006 and complained to medical staff about knee pain and instability 14 times. In 2009, Dr. Ghosh, the prison’s medical director, recommended that Diggs be assigned to a lower bunk and ordered an MRI, which revealed that his right ACL had a complete tear. Ghosh got approval from Wexford, the private company that contracts with Illinois to provide prison medical care, for Diggs to receive orthopedic follow‐up. Notwithstanding recommendations by the outside providers, Diggs received no physical therapy and no follow‐up. After several delays and changes in staff, Diggs unsuccessfully filed an emergency grievance, requesting surgery and complaining that his placement effectively confined him to his cell. In 2015, a Wexford physician reportedly stated that no local doctor would perform the surgery. Diggs sued, alleging that the doctors and warden were deliberately indifferent to his torn ACL and intentionally had caused him emotional distress. He sought an injunction to compel the warden to authorize surgery. The district court granted summary judgment for all defendants, finding that the doctors had treatment choices and that Diggs did not establish that the warden knew about the supposed mistreatment nor that the defendants’ conduct was extreme and outrageous. The Seventh Circuit vacated in part, finding that a reasonable jury could rule in favor of Diggs on the deliberate indifference claims. View "Diggs v. Ghosh" on Justia Law