Antonio Sustaita v. Allen Henderson, 19-3316

Sustaita, an Illinois inmate, tore his left biceps tendon playing soccer in Sept. 2014; Dr. Kul Sood treated him conservatively (pain meds, bandage, low-bunk) and symptoms resolved.
In Dec. 2014 Sustaita fell in segregation, reinjured the biceps (and alleged collarbone fracture). A nurse saw him same day and gave pain meds; Dr. Sood examined him five days later and renewed conservative treatment (pain meds, 60-day low-bunk, bandage wrap), but security rules prevented immediate receipt of the wrap while in segregation.
Over the next ~11 months Sustaita claims repeated complaints, but his medical records show no further biceps or collarbone complaints or diagnoses.
After a third biceps injury following transfer to Stateville, an orthopedist gave a steroid injection, prescribed anti-inflammatories, and noted a longstanding rupture from about one year earlier that "cannot be addressed."
Sustaita sued medical staff and officers for deliberate indifference; the district court granted summary judgment for defendants, finding Dr. Sood’s care constitutionally adequate and other defendants not personally responsible. Sustaita appealed; the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Delay in care after Dec. 2014 fall	No care until Dr. Sood saw him 5 days later	Nurse saw him same day and provided pain meds	No Eighth Amendment violation — same-day nurse care was adequate
Failure to provide bandage wrap promptly	Sood prescribed a wrap but did not ensure immediate delivery	Security policy barred bandages in segregation; Sood followed protocol	No deliberate indifference — Sood constrained by legitimate security protocol
Alleged collarbone fracture ignored	Sustaita says he fractured collarbone and was ignored	No medical diagnosis or records; plaintiff is a layperson	Not a "serious" medical need as required for Eighth Amendment claim
Failure to refer to specialist after second injury	A specialist referral then could have prevented long-term rupture	Conservative treatment was reasonable and had worked previously	No constitutional violation — decision to continue conservative care was within professional judgment; other staff not personally liable

Wilson v. Adams, 901 F.3d 816 (7th Cir. 2018) (summary-judgment/viewing facts in plaintiff's favor standard)
Dobbey v. Mitchell-Lawshea, 806 F.3d 938 (7th Cir. 2015) (prompt nursing attention can satisfy Eighth Amendment)
Burks v. Raemisch, 555 F.3d 592 (7th Cir. 2009) (security protocols may justify delay or restriction of prescribed items)
Foelker v. Outagamie Cnty., 394 F.3d 510 (7th Cir. 2005) (definition of a "serious" medical need)
Gutierrez v. Peters, 111 F.3d 1364 (7th Cir. 1997) (layperson standard for obvious serious medical needs)
Sain v. Wood, 512 F.3d 886 (7th Cir. 2008) (Eighth Amendment review asks whether no minimally competent professional would have so responded)
Cairel v. Alderden, 821 F.3d 823 (7th Cir. 2016) (unsworn complaints and inadmissible hearsay cannot create triable issues)
Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (prisoners do not have a right to demand specific treatment)