Daniel v. Cook County
833 F.3d 728
| 7th Cir. | 2016Background
- Daniel, a 2010 pretrial detainee at Cook County Jail, sues Cook County Sheriff’s Office, Sheriff Dart, and Cook County under §1983 for inadequate health care under the Fourteenth Amendment.
- The case centers on whether the 2008 Department of Justice investigation findings about Cook County Jail health care are admissible as evidence of an unconstitutional custom or policy.
- The district court excluded the DOJ Report as hearsay for truth but allowed it to show notice; the Seventh Circuit reverses on admissibility grounds and addresses its use for notice.
- Daniel presented extensive evidence of systemic scheduling and record-keeping failures and delays in care, including his own medical timeline and staff testimony.
- The court reviews summary-judgment posture de novo and must determine whether Daniel has shown a moving-force link between the jail’s systemic deficiencies and his injury, with potential liability for Sheriff Dart personally.
- The court ultimately reverses the grant of summary judgment and remands for trial, while clarifying admissibility of the DOJ Report under Rule 803(8).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Daniel proved Monell liability for systemic health-care failures. | Daniel shows a general pattern of scheduling/record-keeping failures and sheriff’s notice. | Defendants argue lack of single causative defendant and no policy evidence. | Yes; a genuine issue of material fact exists on Monell liability. |
| Whether the Sheriff's Office/Sheriff Dart can be liable under §1983. | Dart had notice of systemic deficiencies and failed to act. | Supervisory liability requires direct awareness and failure to act; no individual liability without policy. | Sheriff Dart may be liable in his personal capacity. |
| Whether the Department of Justice Report and related documents are admissible under Rule 803(8) for the truth of their findings. | Report should be admitted as a factual finding from a legally authorized investigation. | Report is hearsay for truth and should be excluded. | DOJ Report admissible under Rule 803(8)(A)(iii) for the truth of its findings. |
| Whether the Agreed Order and Shansky Monitor Report can be admitted for the truth of their contents. | These documents are relevant to notice and systemic issues. | Judicial notice or hearsay concerns apply; not admissible for truth of content. | Agreed Order and Monitor Report excluded as hearsay for truth; may be admissible for notice. |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (establishes municipal §1983 liability for official policy or custom)
- Dixon v. County of Cook, 819 F.3d 343 (7th Cir. 2016) (requires moving-force showing for Monell claims)
- Thomas v. Cook County Sheriff’s Dept., 604 F.3d 293 (7th Cir. 2009) (discusses policy and custom in Monell context)
- Rice v. Correctional Medical Services, 675 F.3d 650 (7th Cir. 2012) (due process duty in custodial health care; non‑vicarious liability principles)
- Estelle v. Gamble, 429 U.S. 97 (1976) (constitutional standard for health care in prisons)
- King v. Kramer, 680 F.3d 1013 (7th Cir. 2012) (clarifies duties in large custodial systems)
- Shields v. Illinois Dept. of Corrections, 746 F.3d 782 (7th Cir. 2014) (discusses applicability to private contractors in Monell-like contexts)
- Wellman v. Faulkner, 715 F.2d 269 (7th Cir. 1983) (policy-making knowledge and failure to correct deficiencies)