Earnest D. Shields v. Illinois Department of Correct
746 F.3d 782
| 7th Cir. | 2014Background
- Shields, an Illinois prisoner, sustained a left shoulder pectoralis tendon rupture in 2008 while lifting weights.
- Despite MRI-confirmed injury, he did not receive timely surgery due to oversights and delays by Hill Correctional Center staff and Wexford employees.
- Wexford Health Sources contracted to provide inmate medical care; four Wexford doctors treated Shields.
- SIU School of Medicine doctors examined Shields and recommended physical therapy over surgery.
- The district court granted summary judgment on constitutional claims; post-judgment Rule 60 motion to add state-law malpractice claims was denied; appeal challenged both rulings.
- The court ultimately affirmed, holding that there was no individual liability under §1983 and that Monell-like liability for a private corporation was not extended in this case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Monell extends to private corporations under §1983 | Shields argues corporate liability via policy/custom | Wexford contends no Monell-like liability for private firms | Monell not extended to private corporations (as to Wexford) |
| Whether individual Wexford doctors were deliberately indifferent | Shields alleges each doctor knew and ignored risk | No evidence a doctor knew and disregarded; opinions differed on treatment | No triable issue against Funk, Migliorino, Shute, or Schaefer as to deliberate indifference |
| Whether SIU doctors acted under color of state law under §1983 | SIU doctors caused constitutional deprivation | Olysav and Froelich had only incidental, transitory state relation | No state-action; §1983 claims against SIU defendants properly dismissed |
| Whether the Rule 60 motion to amend adding malpractice claims was timely | Rule 60 motion to amend should relate back; not prejudicial | Motion untimely; prejudice to defendants; not properly appealed | Untimely appeal; post-judgment Rule 60/Rule 15(b) issues barred |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (established policy/custom standard for municipal §1983 liability; not self-evidently extending to private corporations)
- Iskander v. Village of Forest Park, 690 F.2d 126 (7th Cir. 1982) (private corporations not vicariously liable under §1983; Monell extension questioned)
- Adickes v. S.H. Kress & Co., 398 U.S. 144 (1970) (private entity may be liable under §1983 where it aids state actors)
- Lugar v. Edmondson Oil Co., Inc., 457 U.S. 922 (1982) (basis for private party liability under §1983 where state action is shown)
- Richardson v. McKnight, 521 U.S. 399 (1997) (distinguishes private actors from municipalities in immunity context; relevance to private corporations under §1983)