Jocelyn Chatham v. Randy Davis, 839 F.3d 679

McDonald died after an asthma attack at Pinckneyville Correctional Center; his estate sued the warden, Wexford Health Services, Dr. Larson, Nurse Reuter, and guards under 42 U.S.C. § 1983 for deliberate indifference under the Eighth Amendment.
The magistrate granted summary judgment for Warden Davis and Wexford; remaining claims went to a jury who ruled for the other defendants.
The § 1983 claims focus on (a) lack of a permanent medical director and (b) absence of emergency call buttons in the segregation unit, as well as training in asthma emergencies.
Drs. Wahl and Larson treated McDonald; Larson slept through Nurse Reuter’s call but later participated in care; McDonald was transported to a hospital and died minutes after intubation.
Chatham appeals the summary judgment ruling and the denials of leave to amend, discovery sanctions, and a new-trial motion; the Seventh Circuit affirms all challenged orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment deliberate indifference against Warden and Wexford	Chatham alleges actual knowledge of risk and disregard.	No evidence of actual knowledge or substantial risk; negligence not enough.	Affirmed summary judgment for Warden and Wexford.
Monell municipal liability against Wexford	Policy, practice, or custom caused the injury.	No evidence of a policy or custom causing harm; insufficient evidence of widespread risk.	Affirmed denial of Monell liability.
Motion to amend complaint	Late amendment would relate to related state-law claims with little prejudice.	Delay unjustified; undue prejudice to Reuter and Larson.	Affirmed denial of leave to amend.
Discovery sanctions and new-trial motion	Discovery delay and expert-testimony limits harmed Chatham; new trial warranted due to evidentiary issues.	No bad faith; limits were even-handed; no basis for new trial.	Affirmed denial of discovery sanctions and denial of new trial.

Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference requires knowledge of substantial risk and disregard)
Farmer v. Brennan, 511 U.S. 825 (1994) (subjective awareness standard for deliberate indifference)
Duckworth v. Ahmad, 532 F.3d 675 (7th Cir. 2008) (framework for medical deliberate-indifference claims)
Monell v. Dept. of Social Services, 436 U.S. 658 (1978) (municipal liability requires a policy or custom causing injury)
Calhoun v. Ramsey, 408 F.3d 375 (7th Cir. 2005) (custom or practice requires more than a single incident normally)
Woodward v. Corr. Med. Servs. of Ill., Inc., 368 F.3d 917 (7th Cir. 2004) (obvious risk may, in narrow circumstances, show deliberate indifference without multiple incidents)
Shick v. Ill. Dep’t of Human Servs., 307 F.3d 605 (7th Cir. 2002) (evidentiary rulings reviewed for abuse of discretion in trial setting)
Cobige v. City of Chicago, 651 F.3d 780 (7th Cir. 2011) (damages proof with character evidence in wrongful-death context)