Lane v. Neal
3:18-cv-00011
| N.D. Ind. | Mar 20, 2018Background
- Plaintiff Willie Lane, a pro se prisoner, alleges a chronic leg injury preventing him from climbing stairs and has a medical pass for a low-floor cell.
- In October 2017 the segregation unit was moved to fourth and fifth floors; Lane requested reassignment to a low-floor cell in November 2017.
- Unit Team Manager Dawn Buss allegedly told Warden Ron Neal that Lane did not have a medical pass (which Lane says was false) and refused to move him to a low-floor cell.
- Lane informed Warden Neal of the error; Neal requested a copy of the medical pass but took no other action alleged to be deliberately indifferent.
- Lane sued under 42 U.S.C. § 1983 claiming Eighth Amendment deliberate indifference to serious medical needs; the court screened the complaint under 28 U.S.C. § 1915A.
- The court allowed a deliberate-indifference claim to proceed against Buss in her individual capacity for money damages and dismissed claims against Neal and Assistant Warden Payne and all other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants were deliberately indifferent to a serious medical need (Eighth Amendment) | Lane: his stair inability is a serious medical need and defendants prevented his low-floor placement despite a medical pass | Neal and Payne: they were not personally aware or acted reasonably (Neal requested documentation); Buss: disputed factual accuracy | Court: Lane stated a deliberate-indifference claim against Buss (false info/refusal to move). Claims against Neal and Payne dismissed for lack of deliberate-indifferent conduct |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints construed liberally)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment requires adequate medical care)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective awareness of risk)
- Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (definition of serious medical need)
- Savory v. Lyons, 469 F.3d 667 (7th Cir. 2006) (elements of § 1983 claim)
- Board v. Farnham, 394 F.3d 469 (7th Cir. 2005) (deliberate indifference as intentional or criminally reckless conduct)