Levi A. Lord v. Joseph Beahm, 952 F.3d 902

On December 10, 2017, inmate Levi Lord exposed himself to Correctional Officer Lisa Stoffel; Stoffel told him he'd receive a conduct report and left his cell.
Lord then shouted that he had a razor blade and would kill himself; two fellow inmates say they heard the threat, while three officers deny hearing it and one (Pass) acknowledges hearing a threat tied to Stoffel.
About 30 minutes later Officer O'Neal observed blood droplets, secured a razor Lord displayed, removed him from the cell, and medical staff treated a few minor scratches with gauze.
Lord sued four officers under 42 U.S.C. § 1983, alleging Eighth Amendment deliberate indifference to a substantial risk of suicide because they did not respond faster to his threat.
The district court granted summary judgment for defendants, finding Lord presented only minor self-inflicted injuries and that his threat appeared insincere and intended for attention.
The Seventh Circuit affirmed, concluding that even accepting disputed testimony favoring Lord, he produced no cognizable injury to support § 1983 damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers were deliberately indifferent to a substantial risk of suicide	Lord: officers heard his suicide threat and ignored it, creating constitutional liability	Officers: disputed hearing the threat; response was reasonable; threat was insincere and self-inflicted injuries were minor	Even if some officers heard the threat, Lord produced no recoverable injury and the threat was insincere; summary judgment affirmed
Whether a risk alone (without injury) supports § 1983 damages	Lord sought damages for the risk to his life created by officers' inaction	Defendants: § 1983 requires proof that the constitutional violation caused injury/damages	Court: § 1983 is a tort requiring injury; risk alone without cognizable harm is not compensable

Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for prison officials facing a substantial risk of harm)
Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (elements for § 1983 deliberate-indifference Eighth Amendment claim)
Lisle v. Welborn, 933 F.3d 705 (7th Cir. 2019) (prison officials cannot ignore a known suicide risk)
Woodward v. Corr. Med. Servs. of Ill., Inc., 368 F.3d 917 (7th Cir. 2004) (need for diligent precautions to mitigate suicide risk in prison operations)
Wilson v. Garcia, 471 U.S. 261 (1985) (§ 1983 provides a remedy for injuries to personal rights)
Gabb v. Wexford Health Sources, Inc., 945 F.3d 1027 (7th Cir. 2019) (plaintiff must show that a constitutional violation caused injury/damages)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for determining genuine disputes of material fact on summary judgment)