Jones v. Obaisi
1:15-cv-07963
N.D. Ill.Aug 22, 2016Background
- Plaintiff Brian Jones, an inmate at Stateville Correctional Center, alleges deliberate indifference to medical needs under 42 U.S.C. § 1983, complaining of leg pain, throat pain, rectal bleeding, and post‑surgical wound issues from a December 31, 2015 abscess removal.
- Plaintiff filed a pro se Motion for Medical Injunction and, through counsel, a Motion for a Preliminary Injunction seeking: outside specialist appointments, follow‑up care for his surgery, and effective pain medication.
- Defendants submitted medical records and an affidavit (Dr. Obaisi) showing diagnoses (obesity, diabetes, hypertension, allergies, asthma) and multiple treatments and medications through February 7, 2016; records show post‑op wound inspections and some refusals by Plaintiff to be seen.
- Plaintiff submitted later grievances alleging requests for effective pain medication were refused after the defendants’ submitted records cutoff.
- The court applied the preliminary injunction standard (irreparable harm, inadequate remedies, likelihood of success) and the PLRA requirement that injunctive relief be narrow and least intrusive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Outside appointment for leg/throat conditions | Jones says Defendants failed to diagnose/treat and should send him to an outside specialist | Defendants contend Jones has received proper treatment and diagnosis; no likelihood of success | Denied — records show diagnoses and varied treatments; no deliberate indifference shown |
| Effective pain medication | Jones alleges ongoing extreme pain and that requested/needed medications were denied after Feb 2016 | Defendants did not substantively contest this claim in the record before the court | Granted — Jones showed irreparable harm, inadequate remedies, and some likelihood of success; balance of harms favors him |
| Follow‑up specialist for Dec 31, 2015 surgery | Jones seeks outside specialist follow‑up for surgical wound care | Defendants noted post‑op care and later scheduled an appointment | Denied as moot — an August 1, 2016 appointment was scheduled |
Key Cases Cited
- BBL, Inc. v. City of Angola, 809 F.3d 317 (7th Cir. 2015) (preliminary injunction factors and balancing)
- Girl Scouts of Manitou Council, Inc. v. Girl Scouts of U.S. of Am., Inc., 549 F.3d 1079 (7th Cir. 2008) (preliminary injunction standards)
- Westefer v. Neal, 682 F.3d 679 (7th Cir. 2012) (PLRA limits on injunctive relief in prisons)
- Graham v. Medical Mutual of Ohio, 130 F.3d 293 (7th Cir. 1997) (mandatory injunctions are disfavored)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard under the Eighth Amendment)
- Pyles v. Fahim, 771 F.3d 403 (7th Cir. 2014) (deference to medical judgment unless no minimally competent professional would agree)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment and prisoners’ medical care)
- Sain v. Wood, 512 F.3d 886 (7th Cir. 2008) (evaluation of medical treatment decisions and deliberate indifference)
- Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (persisting in known ineffective treatment can violate the Eighth Amendment)
