John Swanson v. Gregg Scott, 695 F. App'x 155

Background

For 23 days in summer 2013, two of three compressors serving a sealed housing unit at Rushville failed, leaving only one insufficient compressor and causing internal temperatures to rise (electronically logged peak ~85°F). Repairs required purchasing two $10,000 compressors; procurement and installation occurred within about ten days after the second failure.
Over 30 residents filed § 1983 suits alleging Fourteenth Amendment deliberate indifference to extreme heat; the district court consolidated the cases and granted summary judgment to defendants; three plaintiffs (Rogers, Paige, Swanson) appealed.
Defendants continuously ran ventilation, used industrial fans in the dayroom, authorized extra outdoor/air-conditioned access on a rotating basis, provided water and limited extra ice, expedited fan purchases and loaned fans to two residents who requested them, and sought prompt approval to buy new compressors once repair was deemed impossible.
Plaintiffs claimed high temperatures (some alleging >100°F), humidity from showers, medical vulnerability (diabetes, obesity, breathing issues), limited access to extra ice/fans/yard, and inadequate staff response; none of the three appellants submitted a grievance or a medical request during the outage or identified a specific ignored request to a defendant.
The district court found the conditions uncomfortable but not sufficiently serious to constitute a constitutional violation and alternatively held that no reasonable jury could find defendants acted with deliberate indifference given their repair efforts and accommodations.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the heat conditions amounted to a "sufficiently serious" deprivation under the Fourteenth Amendment	Heat reached ≥80°F (plaintiffs say sometimes >100°F), humidity worsened risks, and plaintiffs’ medical conditions made them vulnerable	Peak ~85°F, access to water, showers, dayroom, outdoor/AC areas, ice, fans for those who requested; outage was temporary and repairs were pursued promptly	Court: Conditions were uncomfortable but not shown to be constitutionally serious on this record
Whether defendants acted with deliberate indifference to serious medical/environmental needs	Defendants delayed effective relief; lawsuits prompted additional measures; staff ignored residents’ complaints	Defendants attempted repairs immediately, sought procurement approval quickly, provided ventilation, fans, ice, and access; few written complaints and resident requests were honored	Court: No genuine dispute that defendants consciously disregarded a known excessive risk; summary judgment for defendants affirmed
Whether plaintiffs were denied discovery necessary to oppose summary judgment	Plaintiffs contend they lacked discovery and were prevented from showing disputed facts	Plaintiffs did not file Rule 56(d) affidavits or request more time; court had ordered broad disclosure and allowed individual responses	Court: No denial of discovery; plaintiffs failed to seek or show needed discovery
Whether plaintiffs’ medical conditions created a triable issue of fact as to vulnerability	Plaintiffs say preexisting conditions increased risk of harm from heat	Only one resident sought medical care; appellants did not submit grievances or specific requests for accommodation tied to their conditions	Court: Medical vulnerability unaccompanied by requests for assistance or medical complaints did not create a triable deliberate-indifference claim

Key Cases Cited

Youngberg v. Romeo, 457 U.S. 307 (recognizing higher standard of care for civilly confined persons)
Sain v. Wood, 512 F.3d 886 (7th Cir.) (standard for conditions-of-confinement deliberate indifference)
Dixon v. Godinez, 114 F.3d 640 (7th Cir.) (upholding summary judgment on heat-related Eighth Amendment claim)
Del Raine v. Williford, 32 F.3d 1024 (7th Cir.) (discussing requirement that conditions need not be imminently life-threatening to be serious)
Haywood v. Hathaway, 842 F.3d 1026 (7th Cir.) (deliberate indifference requires awareness of sufficiently serious conditions)
Whiting v. Wexford Health Sources, Inc., 839 F.3d 658 (7th Cir.) (standard of review for summary judgment in prisoner/ detainee claims)
Hinojosa v. Livingston, 807 F.3d 657 (5th Cir.) (contrast: sealed windows and >90°F can support Eighth Amendment claim)
Carroll v. Lynch, 698 F.3d 561 (7th Cir.) (summary judgment requires nonmoving party to produce evidence contradicting movant)