Bruce Giles v. Salvador Godinez
914 F.3d 1040
| 7th Cir. | 2019Background
- Plaintiff Bruce Giles, a person diagnosed with schizoaffective disorder, was incarcerated in Illinois and housed at multiple facilities (Dixon, Illinois River, Stateville, Pontiac, Lawrence) during 2010–2012. He had a history of hallucinations, suicide attempts, and prescriptions for psychotropic medications.
- Giles experienced interruptions or changes in medication around transfers (notably a two-week lapse in November 2010 owing to an omitted transfer summary) and alleged other brief medication delays and inconsistent access to programs while in segregation.
- Giles was placed in segregation at multiple facilities after inmate altercations; he alleges segregation conditions (vermin, filth, isolation, violent cellmates) exacerbated his mental illness and contributed to suicidal conduct and physical assaults.
- He filed at least 19 grievances about medical care, medication delays, segregation conditions, and safety; several grievances received emergency review and were denied on administrative appeal.
- Giles sued under 42 U.S.C. § 1983 alleging (1) Eighth Amendment deliberate indifference to serious medical needs, (2) unconstitutional conditions of confinement, and (3) failure to protect; the district court granted summary judgment for nine non-medical prison officials, concluding they reasonably relied on medical professionals.
- On appeal the Seventh Circuit affirmed: it held Giles met the objective element (serious medical need) but failed to show defendants (non-medical officials) possessed the requisite culpable state of mind because they deferred to treating medical professionals and had no notice of mistreatment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether non-medical officials were deliberately indifferent to Giles's serious medical needs | Giles: medication interruptions and inadequate treatment/monitoring show officials knew of and disregarded risk | Defendants: they relied on medical staff; records show regular mental-health care and no obvious mistreatment | Affirmed for defendants — Giles proved objective need but not subjective deliberate indifference |
| Whether segregation conditions violated the Eighth Amendment given Giles's mental illness | Giles: segregation conditions (vermin, filth, isolation, violent cellmates) exacerbated his illness and together created an excessive risk | Defendants: conditions did not deprive minimal civilized necessities; medical staff repeatedly approved segregation placement | Affirmed for defendants — objective deprivation not shown and no subjective culpability |
| Whether defendants failed to protect Giles from other inmates (assaults in mess hall/segregation) | Giles: defendants failed to protect him from assaults tied to his symptoms and segregation placement | Defendants: no notice that specific inmates posed danger; investigations and segregation were used after incidents | Not separately sustained on appeal (related failure-to-protect claim did not overcome lack of notice/culpability) |
| Whether district court abused discretion on motions to recruit counsel and appoint expert | Giles: needed counsel and expert to develop claims and oppose summary judgment | Court/Defendants: court solicited volunteer counsel repeatedly, found none, and denial of expert at summary stage was proper because case failed on legal culpability, not technical medical fact | No abuse of discretion — court reasonably sought volunteers and permissibly denied expert at summary stage; courts should, if search is exhausted, consider notifying pro se litigant and granting limited continuance before ruling on dispositive motion |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to medical needs standard)
- Rhodes v. Chapman, 452 U.S. 337 (conditions-of-confinement must not inflict wanton and unnecessary pain)
- Hudson v. McMillian, 503 U.S. 1 (extreme deprivations required for conditions claim)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir.) (non-medical officials may rely on medical staff absent reason to believe mistreatment)
- Hayes v. Snyder, 546 F.3d 516 (7th Cir.) (summary judgment for non-medical officials who relied on medical judgment)
- Wilborn v. Ealey, 881 F.3d 998 (7th Cir.) (scope of district court's obligation and limits when recruiting volunteer counsel)