Shawn Eagan v. Michael Dempsey
987 F.3d 667
7th Cir.2021Background
- Plaintiff Shawn Eagan, an inmate with diagnosed serious mental illnesses, engaged in repeated self-harm while on crisis watch at Pontiac Correctional Center (Nov. 30–Dec. 2, 2014); staff administered forced injections (Haldol + Benadryl) on Nov. 30.
- Eagan asserts post-injection symptoms (stiffness, then a locked-open jaw) on Dec. 1–2 and alleges medical deliberate indifference by Dr. Dempsey and failure-to-protect and deliberate-indifference claims against several correctional officers and a CMT.
- Eagan repeatedly requested recruitment/appointment of counsel, citing limited education, mental illness, reliance on a now-absent jailhouse lawyer, transfer to a different facility, and the imminent complexity of discovery and expert proof. The district court denied counsel repeatedly, finding Eagan competent and the case not overly complex.
- Defendants moved for summary judgment; the district court granted summary judgment for all defendants, concluding Eagan offered no admissible evidence of deliberate indifference and officers properly relied on medical judgments.
- On appeal the Seventh Circuit held the district court departed from Pruitt in evaluating counsel requests and abused its discretion overall; it found prejudice vis-à-vis Eagan’s claims against Dr. Dempsey and vacated/remanded that part of the judgment, but affirmed summary judgment for the officer defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying appointment/recruitment of counsel under 28 U.S.C. §1915(e)(1) | Eagan had made reasonable attempts to obtain counsel, suffers mental illness, lacks education/litigation skill, lost jailhouse-lawyer assistance after transfer, and faces complex discovery and expert issues | District court: Eagan’s filings were cogent and responsive, claims not novel/complex, and Eagan could conduct "simple" discovery and testify | Abuse of discretion: court materially deviated from Pruitt’s required, particularized analysis; counsel denial was erroneous overall (but disposition varies by claim) |
| Whether denial of counsel prejudiced Eagan (i.e., likely changed outcome) | Assistance would have aided discovery, deposed witnesses (including Dr. Dempsey), and obtained expert proof to rebut defendant records/medical judgments | Defendants: available contemporaneous records (logs, medical notes) contradicted Eagan; counsel unlikely to overcome those records | Prejudice found as to claims against Dr. Dempsey (reasonable likelihood counsel could have altered outcome); prejudice not found as to officer claims |
| Whether summary judgment for Dr. Dempsey was proper on Eighth Amendment deliberate-indifference theory | Dr. Dempsey withheld treatment and may have left Eagan in pain to "teach him a lesson"; contemporaneous records and Dempsey’s intent require probing (deposition, expert) | Dempsey: medical judgment to administer and observe was reasonable; contemporaneous notes show normal jaw motion and tolerance; differences are malpractice, not constitutional | Summary judgment vacated and remanded as to Dempsey to permit further development (discovery/deposition/expert) because counsel could have meaningfully pursued state of mind and medical-reasonableness issues |
| Whether summary judgment for the officer defendants was proper | Officers returned Eagan to cell knowing prior self-harm and later mocked/dismissed his complaints, failing to protect and (Sullivan) denying medical aid for locked jaw | Officers: they relied on medical orders (Dr. Dempsey), promptly sought/obtained medical care, and had no reason/skill to second-guess medical judgments | Summary judgment affirmed as to officers: record lacked evidence they knew of and disregarded a substantial risk or were deliberately indifferent; no reasonable likelihood counsel would have changed that outcome |
Key Cases Cited
- Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (en banc) (framework for recruiting counsel under §1915(e)(1): efforts to obtain counsel then competency/case difficulty analysis)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate-indifference standard requires objective risk and subjective awareness)
- Estelle v. Gamble, 429 U.S. 97 (1976) (medical treatment claims require deliberate indifference, not mere malpractice or disagreement over care)
- Scott v. Harris, 550 U.S. 372 (2007) (courts may disregard a party’s version of events when blatantly contradicted by the record; narrow application to irrefutable evidence)
- Dewitt v. Corizon, Inc., 760 F.3d 654 (7th Cir. 2014) (appointment-of-counsel principles and prejudice analysis in prisoner-medical cases)
- James v. Eli, 889 F.3d 320 (7th Cir. 2018) (assistance of counsel becomes more important as a case advances; complexity increases over discovery and trial)
- Navejar v. Iyiola, 718 F.3d 692 (7th Cir. 2013) (transfer to another facility can substantially impair a pro se plaintiff’s ability to litigate and supports appointment-of-counsel analysis)
- Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (non-medical officials may rely on medical staff unless they know medical care is inadequate)