Richard Budd v. Edward Motley, 2013 U.S. App. LEXIS 6557

Budd, a pretrial detainee, sues under 42 U.S.C. § 1983 alleging unconstitutional jail conditions and deliberate indifference to medical needs at Edgar County Jail.
Alleged conditions include overcrowding, unsanitary cells, broken windows, no running water, mold, and lack of heating, bedding, and recreation.
Budd asserts jail officials created or tolerated these conditions and that the sheriff was deliberately indifferent to his medical needs; district court dismissed for failure to state a claim but did not provide a written explanation or transcript of the screening conference.
On appeal, the Seventh Circuit reviews de novo, holding the conditions claim viable but the medical-indifference claim not, and remanding for counsel-appointment ruling.
The appellees were not served in the district court and did not participate in the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the conditions of confinement claim states a Fourteenth Amendment claim for pretrial detainees.	Budd alleges overcrowding, unsanitary conditions, and related harms.	Motley and office bear no Monell-like liability for conditions allegedly created by jail practices.	Yes; the conditions claim states a claim for relief.
Whether the claim is analyzed under Eighth Amendment standards as a guide for a due-process claim.	Budd's claim should be evaluated under Eighth Amendment standards for cruel and unusual conditions.	Eighth Amendment framework applies as guide for detainee claims.	Eighth Amendment standards guide analysis for a pretrial detainee.
Whether Budd’s medical-indifference claim is plausibly stated.	Infected leg and medical treatment inadequacies show deliberate indifference.	Budd received hospital care, tests, and monitoring; no indifference.	No; medical-indifference claim fails.
Whether the district court abused its discretion by not ruling on appointment of counsel.	Low education justifies appointment of counsel.	Appointment unnecessary if claim lacks plausibility.	Remand to rule on the motion for appointment of counsel.

Farmer v. Brennan, 511 F.3d 825 (U.S. 1994) (due process standard in confinement cases; minimal necessities)
Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (conditioning of confinement; due process via Eighth Amendment lens)
Gillis v. Litscher, 468 F.3d 488 (7th Cir. 2006) (habitable minimal standards; sanitation, bedding, ventilation)
Vinning-El v. Long, 482 F.3d 923 (7th Cir. 2007) (sanitation and lack of cleaning supplies; combined conditions claim)
Dixon v. Godinez, 114 F.3d 640 (7th Cir. 1997) (fact-intensive inquiry required for heating, cold, duration)
Antonelli v. Sheahan, 81 F.3d 1422 (7th Cir. 1996) (habitable standards; heating and bedding)
Murphy v. Walker, 51 F.3d 714 (7th Cir. 1995) (rehab of confinement conditions; totality approach)
Rice ex rel. Rice v. Corr. Med. Servs., 675 F.3d 650 (7th Cir. 2012) (use of Eighth Amendment framework for detainee claims; medical care context)
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (U.S. 1978) (government entity liability for unconstitutional policies)
Hill v. Shelander, 924 F.2d 1370 (7th Cir. 1991) (official-capacity v. municipal liability)
Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (counsel appointment standards in § 1983 cases)