Arnett v. Webster
2011 U.S. App. LEXIS 18812
| 7th Cir. | 2011Background
- Arnett, a rheumatoid arthritis patient, was imprisoned at Terre Haute and arrived with Enbrel prescribed, which prison officials confiscated.
- Over ten months, Arnett complained repeatedly that Enbrel was needed to control RA; doctors and administrators attempted to obtain non-formulary approval, but Enbrel was not provided until October 2007.
- Dr. Webster, the clinical director, initially treated Arnett with pain meds and sought approvals but did not submit an Enbrel non-formulary request; Arnett alleges continued joint swelling and pain.
- Dr. Wilson, Beighley, and Paul-Blanc, treating Arnett, acknowledged swelling and sought Enbrel but allegedly failed to secure timely approval or alternative effective treatment.
- A rheumatologist (Dr. Davis) instructed resumption of Enbrel; Arnett finally received Enbrel on October 5, 2007, shortly before transfer.
- The district court dismissed non-medical defendants and granted summary judgment for Dr. Webster; the Seventh Circuit vacated in part and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether medical defendants acted with deliberate indifference | Arnett | Wilson/Beighley/Paul-Blanc | Plaintiff stated a claim against medical defendants; genuine dispute remains |
| Whether Webster was personally liable for Arnett's treatment decisions | Arnett | Webster | No personal involvement shown; Webster not liable on summary judgment |
| Whether Beighley and Paul-Blanc can be held liable for delaying treatment | Arnett | Beighley/Paul-Blanc | Plausible claim against Beighley and Paul-Blanc; remanded for further proceedings |
| Whether Parker, a non-medical defendant, can be liable for deliberate indifference | Arnett | Parker | Allegations insufficient; Parker properly dismissed; but should be without prejudice to amendment |
Key Cases Cited
- Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816 (7th Cir. 2009) (deliberate indifference can include delay in access to care)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (constitutional guarantee against deliberate indifference to serious medical needs)
- Johnson v. Snyder, 444 F.3d 579 (7th Cir. 2006) (deliberate indifference requires a culpable state of mind)
- Roe v. Elyea, 631 F.3d 843 (7th Cir. 2011) (deliberate indifference analysis for medical care)
- Duckworth v. Ahmad, 532 F.3d 675 (7th Cir. 2008) (deliberate indifference not medical malpractice; requires more than negligence)
- Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (nonmedical officials may be liable if they ignore significant medical mistreatment)
- Berry v. Peterman, 604 F.3d 435 (7th Cir. 2010) (delay in treatment and inadequate responses can defeat summary judgment)
- McGowan v. Hulick, 612 F.3d 636 (7th Cir. 2010) (delay in medical referrals may state a claim)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (non-medical officials rely on medical staff but may be liable if aware of mistreatment)
- Iqbal v. United States, 556 U.S. 662 (U.S. 2009) (purposeful conduct required for supervisory liability in some contexts)
- Vance v. Peters, 97 F.3d 987 (7th Cir. 1996) (non-medical supervisors liable only with direct involvement or failure to act on notice)