Daryise Earl v. Racine County Jail, 718 F.3d 689

Earl, a Wisconsin inmate, sued Racine County Jail and officers under 42 U.S.C. § 1983 for due process and deliberate-indifference claims.
He was placed on suicide watch for five days after being convicted of first-degree intentional homicide, with restricted possessions, a suicide-proof gown, Styrofoam meals, continuous lighting, and constant monitoring.
The jail described suicide watch as policy-based, required for inmates convicted of serious felonies, and to last until a mental-health professional clears release.
Earl-avowedly claimed he was placed on suicide watch as punishment after another officer allegedly relayed false threats against guards.
While on suicide watch, Earl allegedly suffered an allergic skin reaction to the gown; a nurse treated him and advised continuation of the gown.
Two days after the reaction, Earl was discharged from suicide watch but placed for twelve days in administrative segregation, treated as punishment, then transferred to a state prison; two years later he returned for seven days in segregation for a court appearance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Earl's placement on suicide watch implicated a liberty interest.	Earl contends placement was Petitioner-specific punishment.	Hospitable policy placement protected by law, not a liberty interest due to limited duration and conditions.	No liberty interest implicated; five-day suicide watch and short segregation not constitutionally punitive.
Whether the suicide-watch conditions were 'unusually harsh' enough to trigger due-process protections.	Conditions on suicide watch were more restrictive than general prison life and caused deprivation.	Conditions were not unusually harsh and duration was brief.	Not unusually harsh; five days insufficient to trigger due-process protection.
Whether the alleged deliberate indifference to Earl's allergic reaction supports § 1983 liability.	Officer delay and disregard of medical needs show deliberate indifference.	Nurse promptly treated Earl; medical decision to keep gown unchanged was appropriate.	No deliberate indifference; prompt medical response and deference to medical judgment.

Wilkinson v. Austin, 545 U.S. 209 (U.S. 2005) (long-term isolation requires more than brief segregation to implicate liberty interest)
Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (liberty interests affected by confinement depend on the severity and duration)
Marion v. Columbia Corr. Inst., 559 F.3d 693 (7th Cir. 2009) (short-term administrative segregation generally does not implicate liberty interest)
Townsend v. Fuchs, 522 F.3d 765 (7th Cir. 2008) (separation decisions assessed for impact on liberty interests)
Lekas v. Briley, 405 F.3d 602 (7th Cir. 2005) (up to 90 days in segregation generally does not affect liberty)
Knight v. Wiseman, 590 F.3d 458 (7th Cir. 2009) (courts defer to medical judgments in care decisions)
Lee v. Young, 533 F.3d 505 (7th Cir. 2008) (respect for medical decisions in treatment claims)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (standard for deliberate indifference in medical care)
McGowan v. Hulick, 612 F.3d 636 (7th Cir. 2010) (evidence required to support deliberate-indifference claim)
Wells v. Coker, 707 F.3d 756 (7th Cir. 2013) (assessing factual support in § 1983 claims)