Mario Lloyd v. Scott Moats, 16-3939

In October 2011 Mario Lloyd, a federal prisoner, injured his right foot playing flag football and subsequently complained of persistent pain.
Nurse Ted Wall and Dr. Scott Moats treated Lloyd multiple times; initial diagnoses attributed pain to a bunion and degenerative changes.
X‑rays (taken after initial visits) showed an old, healed midfoot fracture and degenerative joint disease; blood tests were normal.
A later MRI (August 2013) showed only mild degenerative changes; an outside podiatrist (June 2014) recommended diabetic shoes, which the prison denied.
Lloyd sued under Bivens alleging Eighth Amendment deliberate indifference based on delayed diagnostics, misdiagnosis, inadequate treatment, and denial of specialized footwear; the district court granted summary judgment for defendants.
On appeal the Seventh Circuit affirmed, concluding the record showed ongoing, non‑culpable medical care, not deliberate indifference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lloyd's foot pain was a "serious medical need"	Lloyd: foot fracture caused ongoing, serious pain requiring prompt imaging and stronger treatment	Defs: pain attributable to bunion/degeneration; treated appropriately	Court assumed, but did not decide, seriousness because other prongs failed
Whether delay in ordering x‑rays/MRI amounted to deliberate indifference	Lloyd: unexplained, harmful delay in diagnostics prolonged pain	Defs: diagnostics and treatment decisions were reasonable medical judgment	No deliberate indifference—record shows repeated exams, x‑rays, MRI, specialist referral
Whether defendants’ treatment decisions (diagnosis, meds, denial of shoes) showed culpable state of mind	Lloyd: misdiagnosis and refusal of stronger meds/shoes amounted to indifference	Defs: disagreements reflect medical judgment, not intent to harm; podiatrist’s recommendation was not binding	Disagreement with treatment or between doctors does not show Eighth Amendment violation
Whether district court abused discretion in denying appointed counsel and discovery relief	Lloyd: needed counsel and additional discovery (including x‑ray evidence) to prove claim	Defs: Lloyd litigated actively; discovery responses adequate	No abuse of discretion; no prejudice shown and no evidence of discovery misconduct

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference standard)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference requires knowledge of substantial risk)
Petties v. Carter, 836 F.3d 722 (delay in treatment must be inexplicable and harmful to show indifference)
Pyles v. Fahim, 771 F.3d 403 (medical judgment on diagnostics is for clinicians, not courts)
Gutierrez v. Peters, 111 F.3d 1364 (extent of care in record important to deliberate indifference analysis)
Arnett v. Webster, 658 F.3d 742 (prisoners entitled to reasonable measures, not best possible care)
Holloway v. Delaware Cty. Sheriff, 700 F.3d 1063 (prisoner not entitled to choose treatment or self‑diagnose)
Pruitt v. Mote, 503 F.3d 647 (standards for appointment of counsel in prison cases)
Geiger v. Aetna Life Ins. Co., 845 F.3d 357 (district courts have broad discovery management discretion)
Scott v. Chuhak & Tecson, P.C., 725 F.3d 772 (sanctions require willfulness or bad faith)