Jeremy Lockett v. Tanya Bonson, 937 F.3d 1016

Plaintiff Jeremy Lockett, an inmate with sickle cell disease, sued two WSPF medical staff (NP Tanya Bonson and nurse Beth Edge) under 42 U.S.C. § 1983 for Eighth Amendment deliberate indifference to serious medical needs arising from pain-management decisions in late 2016.
In September 2016 Bonson switched Lockett from tramadol to Tylenol #3; records show intermittent missed/refused doses and no persistent complaints until an October 3 sickle-cell crisis that required ER treatment.
ER physician recommended immediate-release oxycodone on October 3; Bonson documented administering a one-time oxycodone dose but returned Lockett to Tylenol #3, citing prior adequate control, substance-abuse concerns, and institutional approval requirements for long-term oxycodone.
Lockett later received hydrocodone after a November ER visit; he also alleged missed medication passes in November and filed a grievance against Nurse Edge, which was dismissed; Lockett asserts he timely appealed but produced no receipt and WDOC has no record of the appeal.
District court granted summary judgment for both defendants: (1) Bonson — no deliberate indifference as her decision fell within professional judgment; (2) Edge — granted because Lockett failed to exhaust administrative remedies under WDOC rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NP Bonson was deliberately indifferent by declining ER oxycodone and continuing Tylenol #3	Bonson knowingly disregarded Lockett’s severe pain and overruled ER physician, causing unnecessary suffering	Bonson exercised professional judgment considering history of substance abuse, prior control on Tylenol #3, risks of opioids, and WDOC approval process	Held for defendant: no deliberate indifference; treatment decision within range of acceptable professional judgment
Whether Nurse Edge’s alleged delay in delivering medication violated the Eighth Amendment (merits)	Edge’s delay caused unnecessary pain; Lockett timely exhausted by appealing the grievance	Edge contends grievance appeal was not filed/received; defendants invoke PLRA exhaustion defense	Held for defendant on procedural grounds: Lockett failed to exhaust available administrative remedies (no receipt, no follow-up inquiry under WDOC rules)

Pyles v. Fahim, 771 F.3d 403 (7th Cir. 2014) (Eighth Amendment protects against grossly inadequate medical care)
Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (deliberate indifference requires objective seriousness and subjective knowledge)
Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate indifference standard requires actual knowledge of substantial risk)
Snipes v. DeTella, 95 F.3d 586 (7th Cir. 1996) (treats disagreements over treatment as medical-judgment claims; deference unless no minimally competent professional would act similarly)
Whiting v. Wexford Health Sources, Inc., 839 F.3d 658 (7th Cir. 2016) (state-of-mind evidence may show deliberate indifference where treatment departs from accepted professional judgment)
Burton v. Downey, 805 F.3d 776 (7th Cir. 2015) (prescribing non-narcotic instead of narcotic within professional judgment does not establish deliberate indifference)
Dole v. Chandler, 438 F.3d 804 (7th Cir. 2006) (exhaustion may be excused where prisoner shows reasonable steps and mail/filing evidence)
Kaba v. Stepp, 458 F.3d 678 (7th Cir. 2006) (prison officials who deprive inmates of complaint-system tools cannot rely on exhaustion to bar suit)