14 F.4th 757
7th Cir.2021Background
- Stewart, an inmate at Dixon Correctional Center, suffered from multiple serious conditions (carpal tunnel, shoulder injuries, cirrhosis, etc.) and required frequent outside medical appointments.
- IDOC policy required a metal "black box" restraint for all inmates transported outside the facility unless a prison medical provider granted an exemption; only the warden could overturn a medical exemption.
- Stewart repeatedly requested exemptions from 2009–2016; some requests were granted by certain providers but many were denied, including repeated denials by Dr. Antreas Mesrobian, Wexford’s medical director.
- When denying exemptions Mesrobian nonetheless examined Stewart, prescribed medication, and made referrals (physical therapy, outside orthopedics).
- Stewart also sent letters and had a brief conversation with Assistant Warden Steele asserting pain from the black box; Steele denied personal knowledge of receiving the letters.
- The district court granted summary judgment for Mesrobian, Wexford, and Steele; the Seventh Circuit affirmed, finding no Eighth Amendment deliberate indifference or municipal/custom liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference by treating physician (Mesrobian) | Black box caused excruciating pain and aggravated conditions; Mesrobian ignored risk by denying exemption | Mesrobian evaluated Stewart, provided meds/referrals, and exercised medical judgment balancing security | No. A difference of medical opinion and measured responses did not show a decision no minimally competent professional would make; not deliberate indifference. |
| Corporate liability (Wexford) for policy or widespread custom | Wexford had a pattern/custom of denying exemptions to inmates like Stewart | Wexford followed IDOC directive and required individualized medical assessments; some exemptions were granted | No. Plaintiff failed to show an unconstitutional policy or well‑settled custom; evidence showed case‑by‑case decisions. |
| Individual liability of Assistant Warden Steele | Steele received letters and a conversation and failed to ensure adequate medical care | Steele reasonably relied on medical staff and lacked medical expertise to override providers | No. No evidence Steele turned a blind eye or was personally responsible; reliance on medical personnel was permissible. |
| Official‑capacity/IDOC policy claim | IDOC lacked sufficiently specific policies on exemptions, causing constitutional harm | IDOC policy delegated exemptions to medical professionals for individualized assessment | No. Delegation to medical judgment is not unconstitutional; no proof of an unconstitutional custom or policy. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment prohibits deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective knowledge and disregard of substantial risk)
- Whitley v. Albers, 475 U.S. 312 (1986) (when security concerns conflict with rights, courts consider need, relationship to force used, and injuries)
- Monell v. Dep't of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipal/corporate liability requires policy, custom, or final policymaker)
- Norfleet v. Webster, 439 F.3d 392 (7th Cir. 2006) (difference of medical opinion does not establish deliberate indifference)
- Payne v. Pauley, 337 F.3d 767 (7th Cir. 2003) (on summary judgment, facts must be viewed in the light most favorable to nonmoving party)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard: no genuine dispute of material fact)
- Pyles v. Fahim, 771 F.3d 403 (7th Cir. 2014) (medical professionals get deference; liability only when treatment is so inadequate no minimally competent professional would have provided it)