MCCLOUD v. CORIZON MEDICAL SERVICES, 2:16-cv-00422

Plaintiff Jeffrey McCloud, a prisoner at Wabash Valley Correctional Facility, alleges Eighth Amendment deliberate indifference to serious medical needs for ongoing left-arm/hand pain from prior injuries and a 2015 stabbing.
He alleges multiple evaluations by Dr. Samuel Byrd (six between Jan–Aug 2015) with continuing complaints of pain and that Corizon’s pre-written treatment protocols prevented appropriate care.
Nurse R. Riggs allegedly denied or delayed access to physicians in response to health care requests and refused to schedule doctor visits or specialty consults.
McCloud seeks compensatory and punitive damages and corrective medical treatment (e.g., hand surgery/repair).
The court screened the complaint under 28 U.S.C. § 1915A and dismissed several defendants (Drs. Raham, Mitcheff, Neil Martin, and Nurse R. Robinson) for lack of personal involvement or because claims against some were time-barred.
Remaining defendants ordered served: Corizon Medical Services, Dr. Samuel Byrd, and Nurse B. Riggs; claims allowed to proceed: (1) denial of treatment outside Corizon’s protocols, (2) deliberate indifference by Dr. Byrd, and (3) deliberate indifference by Nurse Riggs for delaying/denying access to doctors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether medical condition is objectively serious	McCloud: ongoing tendon/nerve damage and post-stabbing pain constitute serious medical needs	Corizon/individuals implicitly contest severity by following protocols and offering limited care	Court assumed seriousness and proceeded on deliberate-indifference framework
Whether defendants were personally involved	McCloud: Corizon, Dr. Byrd, and Nurse Riggs directly withheld or delayed appropriate care	Other named providers had minimal or no involvement; some defendants followed policy or had limited contact	Court dismissed claims against Drs. Raham, Mitcheff, Neil Martin, and Nurse Robinson for lack of personal involvement
Whether actions demonstrate deliberate indifference	McCloud: denial of care outside Corizon’s treatment book, persistent pain, denial/delay of doctor access shows deliberate indifference	Defendants: treatment decisions and scheduling reflect medical judgment or policy; some alleged events predate limitations period	Court allowed claims against Corizon, Dr. Byrd, and Nurse Riggs to proceed on deliberate-indifference theory
Whether claims are time-barred	McCloud: seeks relief for ongoing and recent denials of care	Defendants: any claims based on 2013 treatment decisions are beyond Indiana’s two-year statute of limitations	Court held claims based on 2013 treatment decisions (e.g., Mitcheff/Raham involvement) are time-barred and dismissed those allegations/defendants

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: factual allegations must plausibly show liability)
Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference standard requires subjective awareness of substantial risk)
Lagerstrom v. Kingston, 463 F.3d 621 (7th Cir. 2006) (screening standard for pro se prisoner complaints follows Rule 12(b)(6) principles)
Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (persisting with inappropriate treatment can show deliberate indifference)
Gonzalez v. Feinerman, 663 F.3d 311 (7th Cir. 2011) (continued inadequate treatment may constitute deliberate indifference)
Hollander v. Brown, 457 F.3d 688 (7th Cir. 2006) (complaint may be dismissed under Rule 12(b)(6) if it pleads facts establishing a statute-of-limitations defense)
Richards v. Mitcheff, 696 F.3d 635 (7th Cir. 2012) (§ 1983 actions borrow state personal-injury statute of limitations)