Jones, Leroy v. Foster, Brian
3:19-cv-00106
| W.D. Wis. | Mar 7, 2024Background
- Leroy Jones, an inmate in Wisconsin prisons, sued 13 medical staff and related personnel, alleging deliberate indifference to, and negligence in, his care for chronic knee, back, and foot pain, as well as a finger injury.
- Jones received treatments including medications (Gabapentin, Salsalate, Ibuprofen, and others), steroid injections, physical therapy, special shoes, and consultations with specialists, but believed the care was insufficient or not provided as recommended.
- Claims were brought under the Eighth Amendment for deliberate indifference and under Wisconsin law for negligence.
- Defendants moved for summary judgment on all claims, asserting Jones did not suffer unconstitutional deprivation and that their actions were appropriate under professional standards.
- The court analyzed the motions, focusing first on Eighth Amendment claims before addressing whether to retain jurisdiction over state-law negligence claims.
- The court ultimately entered summary judgment for all defendants on Eighth Amendment claims and declined supplemental jurisdiction over state-law claims, dismissing them without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants were deliberately indifferent to Jones' serious medical needs | Jones was denied or provided inadequate care for pain and injuries; staff ignored specialist recommendations | Defendants provided care consistent with professional judgment, DOC policy, and patient needs; delays or disagreements were not constitutional violations | Court found no deliberate indifference; summary judgment for defendants |
| Whether disagreements between prison and outside medical providers support a constitutional claim | Committee and staff ignored Dr. Choi's and other specialists' recommendations for certain treatments and shoes | Medical staff are not required to follow outside recommendations if reasonable alternatives exist; not unconstitutional to disagree among professionals | Disagreements alone do not support Eighth Amendment liability |
| Whether treatment or medication delays constituted deliberate indifference | Delays in appointments, refills, or following up on injuries caused pain and possible harm | Any delays were brief or explained by policy/practice, with no evidence harm was exacerbated by delay | Delays found not actionable under Eighth Amendment |
| Whether state-law negligence claims should be retained after federal dismissal | Claims should proceed or be considered due to ongoing injury, regardless of federal outcome | Once federal claims are dismissed, court should decline jurisdiction over state-law claims | Court dismissed state-law claims without prejudice |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (establishes deliberate indifference standard under the Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires actual knowledge and disregard of risk)
- Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (totality of medical care is relevant for deliberate indifference)
- Snipes v. DeTella, 95 F.3d 586 (7th Cir. 1996) (judicial deference to medical judgment unless "blatantly inappropriate")
- Giles v. Godinez, 914 F.3d 1040 (7th Cir. 2019) (elements for Eighth Amendment medical care claims)
- Dean v. Wexford Health Sources, Inc., 18 F.4th 214 (7th Cir. 2021) (serious medical need defined)