Padilla v. Dolce
3:25-cv-00196
S.D. Ill.Apr 14, 2025Background
- Damien Padilla, an inmate in the Illinois Department of Corrections, filed a lawsuit under 42 U.S.C. § 1983, alleging deliberate indifference to his serious medical needs while at Menard Correctional Center.
- Padilla claims he suffers from back and leg pain requiring ongoing care, physical therapy, and medication due to prior spinal surgery.
- Between December 2023 and December 2024, Padilla alleges Nurse Connie Dolce, the head nurse and director of nursing, ignored his repeated requests for medical treatment and physical therapy.
- The complaint was subject to preliminary screening under 28 U.S.C. § 1915A to determine if it stated a plausible constitutional claim.
- The court found that Padilla's complaint adequately states an Eighth Amendment deliberate indifference claim against Dolce, allowing the case to proceed.
- Other potential claims, including against Nurse Morgan or under the Fourteenth Amendment, were dismissed without prejudice as inadequately pled.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference to serious medical needs under the Eighth Amendment | Dolce ignored requests for treatment, medication, and PT despite knowledge of serious condition | Not presented at this stage | Sufficiently pleaded; claim proceeds |
| Due process right violation under the Fourteenth Amendment | Mentions due process rights violations | Not applicable at this stage | Not adequately pled; dismissed |
| Claims against Nurse Morgan | Padilla submitted requests to Morgan, not named as a defendant | Not applicable | No claim stated; dismissed |
| Screening legal sufficiency under § 1915A | Complaint states a plausible Eighth Amendment claim | N/A | Complaint passes screening on Count 1 |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates Eighth Amendment)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim for relief)
- Chatham v. Davis, 839 F.3d 679 (delay in medical treatment can support deliberate indifference claim)
- Gomez v. Randle, 680 F.3d 859 (denial or delay of medical care in prison can be actionable under § 1983)