Adrian Thomas v. James Blackard
2 F.4th 716
7th Cir.2021Background:
- In October 2017 Thomas was placed in a cell he described as filthy: feces, urine, and mold on walls and door; a mattress soiled with human waste; about 100 dead flies on the bunk; and a sink that ran cold, black, oily water.
- Thomas complained orally and through grievances and remained in the cell for roughly eight weeks before transfer to another facility.
- Pontiac officials provided a new mattress within two weeks, gloves to remove flies, a towel and at least six cups of disinfectant (which Thomas refused to use to clean the walls), and three hot showers per week while a repair was attempted; water supply testing met environmental requirements.
- For a back rash Thomas saw a health worker who diagnosed a small clogged pore, recommended warm moist compresses (which he obtained using a neighbor’s hot water), and he did not seek further treatment.
- Thomas sued under 42 U.S.C. § 1983 alleging Eighth Amendment deprivations as to cell conditions and medical care; the district court granted summary judgment to defendants Blackard and Punke.
- The Seventh Circuit affirmed, holding that although the conditions were objectively troubling, defendants did not act with deliberate indifference and the skin condition was not an objectively serious medical need.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conditions of confinement — Eighth Amendment | Thomas: cell conditions (feces, soiled mattress, dead flies, no usable hot water) violated Eighth Amendment and officials ignored complaints | Blackard/Punke: they responded reasonably — provided new mattress, gloves, disinfectant, showers, and sought repairs; water met standards | Affirmed summary judgment for defendants: objective conditions could be unconstitutional, but no evidence of deliberate indifference |
| Medical care — Eighth Amendment | Thomas: rash/skin condition required treatment and prison ignored it | Defendants: diagnosis was a minor clogged pore treated with warm compresses; no serious medical need and no deliberate indifference | Affirmed summary judgment for defendants: condition not objectively serious and no deliberate indifference |
Key Cases Cited
- Rhodes v. Chapman, 452 U.S. 337 (establishes objective Eighth Amendment standard for conditions of confinement)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard: subjective awareness plus disregard of substantial risk)
- Taylor v. Riojas, 141 S. Ct. 52 (per curiam) (extreme filth and raw sewage in cells violate Eighth Amendment and are clearly established)
- Estelle v. Gamble, 429 U.S. 97 (medical treatment: Eighth Amendment protects against deliberate indifference to serious medical needs)
- King v. Kramer, 680 F.3d 1013 (7th Cir.) (defines objectively serious medical need threshold)
- Hardeman v. Curran, 933 F.3d 816 (7th Cir.) (sanitation, bedding, and utilities are components of humane confinement)