Allen Caffey v. Lucas Maue, 679 F. App'x 487

Allen Caffey, an Illinois prisoner at Menard, was interviewed by corrections officers about a law-library assault; he refused to cooperate and called two officers “unprofessional.”
After the interview Major Moore placed Caffey in 30 days investigative segregation; he was later told he would be transferred to Pontiac Correctional Center.
While being escorted to a bus, Officer Lucas Maue allegedly struck Caffey on the head with a wooden stick; another inmate submitted an affidavit supporting Caffey’s account.
On the bus, Officer Todd Scott allegedly pressed Caffey’s head against a window while shackling him and ignored Caffey’s verbal requests for medical attention for head pain and ringing; no visible wound was present.
Upon arrival at Pontiac, Caffey’s property was processed after delay by Mary Richard; Caffey later reported missing/damaged items.
Procedural posture: Summary judgment granted to defendants by the district court on all claims; Seventh Circuit affirms in part, vacates and remands excessive-force claim against Maue for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment: punishment for refusal to cooperate and calling officers “unprofessional”	Caffey says segregation, transfer, and property interference were retaliation for protected speech/refusal to cooperate	Defendants say refusal to answer was not privileged and name-calling was insubordinate, and disciplinary actions were for legitimate investigative reasons	Court: speech not protected; First Amendment claim fails
First Amendment: property processing by Richard	Caffey contends Richard damaged/converted property in retaliation	Richard says delay and condition reflect routine backlog and no knowledge of Menard events	Court: no evidence Richard knew of allegations; claim fails
Eighth Amendment: deliberate indifference to medical need (Scott)	Caffey says he communicated head pain and was ignored	Scott says pain reports were vague, no visible injury, and he expected medical personnel at Pontiac	Court: objective seriousness assumed, but no evidence Scott knew extent of injury or consciously disregarded it; claim fails
Eighth Amendment: excessive force (Maue and Scott)	Caffey alleges malicious use of force: baton strike (Maue) and pressing head against window (Scott)	Defendants assert force was minimal/necessary to maintain discipline	Court: Scott’s conduct insufficient for Eighth Amendment claim; Maue’s alleged strike with a wooden stick could be malicious and is remanded for trial

Perez v. Fenoglio, 792 F.3d 768 (7th Cir.) (retaliation elements for prison speech)
Fairley v. Andrews, 578 F.3d 518 (7th Cir.) (prisoners’ First Amendment rights in corrections context)
Turner v. Safley, 482 U.S. 78 (1987) (limits on prisoner speech consistent with institutional needs)
Riggins v. Walter, 279 F.3d 422 (7th Cir.) (prisoners may be compelled to disclose information in investigations absent self-incrimination concerns)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for Eighth Amendment)
Hudson v. McMillian, 503 U.S. 1 (1992) (excessive force — malicious/sadistic inquiry not dependent on significant injury)
Wilkins v. Gaddy, 559 U.S. 34 (2010) (degree of injury not dispositive where force was malicious)
Rice ex rel. Rice v. Corr. Med. Servs., 675 F.3d 650 (7th Cir.) (Eighth Amendment excessive-force factors)
Guitron v. Paul, 675 F.3d 1044 (7th Cir.) (malicious force claim can be actionable without significant injury)
Petties v. Carter, 836 F.3d 722 (7th Cir. en banc) (subjective deliberate-indifference analysis)
Dobbey v. Mitchell-Lawshea, 806 F.3d 938 (7th Cir.) (pain can establish objectively serious medical need)
Carson v. ALL Erection & Crane Rental Corp., 811 F.3d 993 (7th Cir.) (summary-judgment standard)