Henry Barrows v. Lisa Goldman, 20-2475

Background

Henry Barrows, an inmate with schizoaffective disorder, had recent suicide-related behavior and spent ~two weeks on crisis watch at Menard Correctional Center.
Dr. Lisa Goldman placed Barrows on 15‑minute watch, later continuous watch after a bleeding incident, then reduced to 10‑ and 15‑minute intervals as staff observed stabilization.
On Sept. 25 Barrows told counselor Jacob Weatherford he wanted to cut himself; Weatherford assessed him as alert, cooperative, and without a specific plan, and kept him on 15‑minute watch.
Three hours later Barrows made two profusely bleeding cuts requiring hospital treatment; after return, Nurse Cowan evaluated him and Dr. Goldman removed him from crisis watch because he denied suicidal ideation and had recently stabilized.
After Barrows again cut himself in his cell, staff treated the wounds (steri‑strips) and placed him in four‑point restraints; Barrows sued prison mental‑health and medical staff for Eighth Amendment deliberate indifference.
The district court granted summary judgment for defendants; the Seventh Circuit affirmed, finding no evidence of recklessness or departure from professional judgment by the clinicians.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Weatherford was deliberately indifferent by keeping Barrows on 15‑minute watch on Sept. 25	Weatherford recklessly dismissed Barrows’ expressed urge to self‑harm and should have ordered closer supervision or restraints	Weatherford reasonably assessed no imminent risk (alert, cooperative, no plan) and kept standard monitoring; providers get deference	Weatherford: summary judgment affirmed — no evidence of reckless or intentional disregard
Whether Dr. Goldman was deliberately indifferent by removing Barrows from crisis watch after his hospital treatment	Goldman ignored objective risk (recent surgery for severed vein, Barrows’ statement he would harm himself again, prior instability)	Goldman relied on Cowan’s evaluation, Barrows’ denial of suicidal ideation, recent non‑suicidal behavior, and harms of prolonged watch — a reasoned medical judgment	Goldman: summary judgment affirmed — decision within professional judgment, no contrary medical evidence
Whether Nurse Cowan was deliberately indifferent by participating in removal from crisis watch	Cowan failed to recognize or contest the risk and helped return Barrows to less supervision	Cowan lacked authority to remove watch and relied on Dr. Goldman’s professional judgment and her own assessment	Cowan: summary judgment affirmed — no evidence she violated standards or could override medical judgment
Whether treating nurses were deliberately indifferent by using steri‑strips instead of sutures	Barrows contends improper wound care caused harm	Nurses point to treatment choice and rapid healing	District court ruled for nurses; Barrows did not press this claim on appeal

Key Cases Cited

Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate‑indifference standard: must show defendant knew of and disregarded an excessive risk)
Johnson v. Dominguez, 5 F.4th 818 (7th Cir. 2021) (medical providers entitled to deference when they reasonably respond to risks)
Whiting v. Wexford Health Sources, Inc., 839 F.3d 658 (7th Cir. 2016) (absence of medical evidence contradicting provider’s judgment undermines deliberate‑indifference claim)
Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (en banc) (analysis of Eighth Amendment deliberate‑indifference claims against prison medical providers)
Rice ex rel. Rice v. Correctional Medical Services, 675 F.3d 650 (7th Cir. 2012) (limitations on imposing liability for second‑guessing reasonable medical decisions)