Rodney Clemons v. Wexford Health Sources, Inc., 106 F.4th 628

Rodney Clemons, an inmate at Stateville Correctional Center, suffered from chronic pain in his right foot and ankle stemming from a pre-incarceration injury and surgery.
During incarceration, Clemons’s condition worsened, and he repeatedly sought special shoes, pain relief, and a referral to see a podiatrist.
Dr. Obaisi, Stateville’s medical director, treated Clemons with pain medication and special shoes, but did not appeal Wexford’s denials of some shoe requests or immediately refer Clemons to a specialist, allegedly citing cost and referral limits.
Clemons eventually was referred to a podiatrist, received surgery, and continued to face administrative challenges to follow-up care and equipment requests.
Clemons sued Wexford, Dr. Obaisi’s estate, and another doctor under § 1983, alleging deliberate indifference to his serious medical needs in violation of the Eighth Amendment.
The district court granted summary judgment to the defendants, finding insufficient evidence of deliberate indifference or a widespread unconstitutional policy.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Dr. Obaisi’s Delay in Podiatrist Referral	Delay was due to cost, not medical judgment	Referral delay was based on reasonable care	No deliberate indifference; treatment was reasonable
Failure to Appeal Shoe Denials	Obaisi’s failure to appeal was deliberate indifference	No precedent for deliberate indifference for failing to appeal admin denials	No deliberate indifference; no evidence appeal duty
Admissibility of Clemons’s Affidavit	Affidavit valid and expands on record	Affidavit is a sham, contradicts earlier testimony	Affidavit permissible; no abuse of discretion
Wexford’s Corporate Policy Liability	Referral limits show deliberate indifference by policy	Policy not facially unconstitutional; no pattern	No widespread practice shown; not liable under Monell

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal and corporate liability under § 1983 requires unconstitutional policy or practice)
Dean v. Wexford Health Sources, Inc., 18 F.4th 214 (7th Cir. 2021) (clarifying deliberate indifference and Monell liability standards)
Petties v. Carter, 836 F.3d 722 (7th Cir. 2016) (framework for analyzing Eighth Amendment medical care claims)
Whiting v. Wexford Health Sources, Inc., 839 F.3d 658 (7th Cir. 2016) (deliberate indifference requires knowing disregard, not merely suboptimal care)
Pyles v. Fahim, 771 F.3d 403 (7th Cir. 2014) (failure to refer to specialist only actionable if blatantly inappropriate)