Flournoy v. Schomig, 418 F. App'x 528

Flournoy, an Illinois inmate, was housed at Pontiac Correctional Center (2001–2002), a maximum-security facility.
He alleges exposure to pepper-spray fumes at least eight times during this period, which allegedly worsened his glaucoma.
An officer allegedly stated inmates were sprayed to punish gang activity; Gragert allegedly ignored grievances about spray use.
Under policy, the warden must approve pepper spray; a cell-house ranking officer could also approve, with medical rinse available after exposure.
Flournoy also alleges denial of a call to his dying father due to race; hospital verification procedures allegedly blocked forwarding his emergency-call request.
The district court granted summary judgment on multiple claims; on appeal, issues included personal involvement, exhaustion, and equal protection.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Schomig personally involved in pepper-spray exposure?	Schomig knew of and condoned the practice.	Schomig had no knowledge of the practice; no personal involvement.	No personal involvement; affirmed summary judgment.
Was Gragert personally involved in denying medical/grievance relief?	Gragert failed to act on the pepper-spray grievance.	Gragert lacked authority over use-of-force or medical grievances.	Gragert not personally liable; affirmed summary judgment.
Did record evidence support an equal protection claim regarding denial of an emergency call due to race?	Logs destruction would show defendants’ discriminatory conduct.	No showing of intentional destruction or discriminatory intent.	Logs destruction not shown as bad faith; equal protection claim rejected.
Did the district court abuse its discretion in denying amendment to identify unnamed officials given statute of limitations?	Name new defendants discovered via discovery; amendment should relate back.	statute of limitations barred relation back; amendment untimely.	No abuse of discretion; amendment barred by statute of limitations.

Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard limits supervisory-liability theory)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for inmate health/safety)
Berry v. Peterman, 604 F.3d 435 (7th Cir. 2010) (supervisory liability requires personal involvement or responsibility)
Burks v. Raemisch, 555 F.3d 592 (7th Cir. 2009) (state of mind and responsibility tied to deliberate indifference showing)
George v. Smith, 507 F.3d 605 (7th Cir. 2007) (mere inaction insufficient for liability; not a supervisor’s automatic liability)
Norman-Nunnery v. Madison Area Tech. Coll., 625 F.3d 422 (7th Cir. 2010) (bad-faith destruction of records required for inference)
Faas v. Sears, Roebuck & Co., 532 F.3d 633 (7th Cir. 2008) (evidence requirements for adverse inference on claims)
Hall v. Norfolk S. Ry. Co., 469 F.3d 590 (7th Cir. 2006) (relation back and discovery-related amendment standards)