Griffin v. Larson
3:21-cv-00436
S.D. Ill.Sep 23, 2024Background
- Rory Griffin, an Illinois inmate, tore his left bicep muscle while lifting weights at Big Muddy River Correctional Center in April 2019.
- Initial care included ice and a sling; both Dr. Dennis Larson (prison doctor) and Dr. Steven Young (orthopedic surgeon) participated in his treatment for ensuing injuries and complications.
- Griffin underwent three surgeries related to his injury, two performed by Dr. Young (June 2019 bicep repair and August 2020 nerve decompression) and a third by Dr. Mulhern (April 2022 granuloma removal).
- Following each surgery, Dr. Young prescribed Norco for pain, whereas Dr. Larson substituted Tylenol #3; Griffin alleged persistent pain and inadequate care.
- Griffin filed multiple grievances during his course of treatment alleging constitutionally deficient medical care under the Eighth Amendment.
- The court reviewed cross-motions for summary judgment: Dr. Young moved for summary judgment based on failure to exhaust administrative remedies and lack of deliberate indifference; Dr. Larson also sought summary judgment on deliberate indifference grounds.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Administrative exhaustion (PLRA) | Grievances properly exhausted, covering Young | Grievances did not name/discuss Dr. Young specifically | Griffin exhausted remedies as required |
| Deliberate indifference: Dr. Young | Delayed, ineffective treatment; ignored pain | Treatment within accepted standards; no culpable delay | No deliberate indifference by Young |
| Deliberate indifference: Dr. Larson | Unreasonable delay in care; ignored specialist | Treatment based on professional judgment; adequate care | Issue requires jury; summary judgment denied |
| Pain medication substitution post-surgery | Larson ignored Young's Norco prescription | Tylenol #3 was suitable alternative; Norco unavailable | Jury could infer indifference—denied as to Larson |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (sets standard for Eighth Amendment claims of deliberate indifference to medical needs)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires knowledge of and disregard for excessive risk)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (standard for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (burden-shifting on summary judgment)
- Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (deliberate indifference can be inferred from ignoring specialist recommendations or obvious risks)
- Forbes v. Edgar, 112 F.3d 262 (7th Cir. 1997) (Eighth Amendment ensures reasonable, not best, medical care)
- Hayes v. Snyder, 546 F.3d 516 (7th Cir. 2008) (deliberate indifference requires more than negligence)
- Snipes v. DeTella, 95 F.3d 586 (7th Cir. 1996) (difference in medical opinion does not amount to deliberate indifference)