Ross, Michael v. Becker, Shawn, 3:20-cv-00546

Background

Michael T. Ross was arrested Feb 13, 2020, and booked into Wood County Jail; video showed no obvious hand injury at booking and no contemporaneous report of a broken hand.
After being placed on mental-health watch, jail staff later observed his right hand red and swollen; officers told him to submit an inmate health service request under the jail’s nonurgent procedure.
Nurse LPN Alli Nelson (employed by Advanced Correctional Healthcare, later Southern Health Partners) saw Ross in health services on Feb 17, gave Tylenol, noted visible bruising/swelling and limited finger movement, and scheduled an x-ray; hospital x-ray on Feb 18 showed a fractured fifth metacarpal, later casted and fully healed.
Ross was on a preexisting Suboxone taper initiated by the jail’s prior provider; when Southern Health Partners took over (Mar 1), NP Metz continued the taper and prescribed symptomatic meds; Nelson, an LPN, monitored, recorded vitals, and communicated with Metz but lacked authority to change the taper or prescribe Suboxone.
Procedural posture: defendants moved for summary judgment. Court granted summary judgment for Wood County, Sheriff Becker, Officers Baker and King. Court granted in part and denied in part the motion by Southern Health Partners and Nelson: all claims dismissed except Ross’s Fourteenth Amendment claim against Nurse Nelson for allegedly inadequate treatment of his broken hand, which proceeds to trial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Officers Baker and King were deliberately indifferent by not arranging emergency care for Ross's hand on Feb 13	Ross: officers ignored his complaints and visible swelling; should have sought immediate medical care	Officers: no obvious injury at booking, statements contradicted booking, reasonable to use routine health-request process; no signs of severe distress	Court: Summary judgment for Baker and King (no deliberate indifference; actions objectively reasonable)
Whether Nurse Nelson violated the Fourteenth Amendment by providing only Tylenol and delaying further treatment for the broken hand	Ross: Nelson ignored repeated complaints, acknowledged likely break, failed to contact advanced provider, refer to ER, or provide splint/ice; delay was unreasonable	Nelson: disputes timing of complaints; argues lack of expert showing that her actions were objectively unreasonable	Court: Genuine dispute exists whether providing only Tylenol and delaying further care was objectively unreasonable — claim against Nelson re: hand survives summary judgment
Whether Nelson was constitutionally liable for inadequate management of Ross's Suboxone withdrawal	Ross: Nelson knew of severe withdrawal symptoms and failed to arrange adequate care or escalate to provider/ER	Nelson: as an LPN she lacked authority to change taper or prescribe; she monitored, reported to NP Metz, and followed orders; NP Metz prescribed meds	Court: Summary judgment for Nelson on Suboxone claim (her role was limited, and medical judgment questions require expert proof)
Whether Southern Health Partners is liable for constitutional violation relating to Suboxone taper or withdrawal management (policy/custom/final policymaker)	Ross: corporate provider responsible for policies leading to withdrawal management that harmed him	Southern Health Partners: no unconstitutional policy or practice shown; any treatment decisions trace to individual clinical judgments and prior provider orders	Court: Summary judgment for Southern Health Partners (no municipal/corporate liability shown)

Key Cases Cited

Collins v. Al-Shami, 851 F.3d 727 (7th Cir. 2017) (pretrial detainee medical-care claims governed by Fourteenth Amendment standard)
McCann v. Ogle Cty., Illinois, 909 F.3d 881 (7th Cir. 2018) (requires purposeful/knowing/reckless state of mind and objective unreasonableness)
Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018) (Fourteenth Amendment deliberate-indifference framework for pretrial detainees)
Pittman v. County of Madison, Illinois, 970 F.3d 823 (7th Cir. 2020) (distinguishes awareness, strong suspicion, and recklessness for culpable mental state)
Riccardo v. Rausch, 375 F.3d 521 (7th Cir. 2004) (guards need not accept all inmate complaints at face value when assessing medical need)
Miller v. Gonzalez, 761 F.3d 822 (7th Cir. 2014) (at summary judgment courts must view facts in favor of nonmovant)
Lewis v. McLean, 864 F.3d 556 (7th Cir. 2017) (even brief delay can violate Constitution if it exacerbates injury or prolongs pain)
McGowan v. Hulick, 612 F.3d 636 (7th Cir. 2010) (delayed treatment cases and constitutional liability principles)
Williams v. Liefer, 491 F.3d 710 (7th Cir. 2007) (constitutional liability for inadequate medical care can hinge on delay and its effects)
Pulera v. Sarzant, 966 F.3d 540 (7th Cir. 2020) (municipal/corporate liability requires policy, custom, or final policymaker decision)
Glisson v. Indiana Dep't of Corr., 849 F.3d 372 (7th Cir. 2017) (standards for institutional liability for systemic constitutional deprivations)
City of Los Angeles v. Heller, 475 U.S. 796 (U.S. 1986) (no municipal liability where there is no underlying constitutional violation)