Teague v. Tieman, 3:17-cv-00255

Background

Plaintiff Dexter Ramone Teague, a pro se prisoner, alleged inadequate medical care at St. Joseph County Jail from August 2015 to June 2016 for rheumatoid/inflammatory arthritis.
Before incarceration Teague was being treated with methotrexate and prednisone and his specialist was adjusting medications when he was arrested.
On August 15, 2015, Dr. Chris Hall said he was unqualified to adjust Teague’s medications but agreed to contact Teague’s specialist; Teague alleges no further follow-up and persistent pain.
In November 2015 and thereafter Dr. James Tieman also said he was unqualified to adjust medications (and that the specialist would not see Teague in jail) but nonetheless adjusted Teague’s medications intermittently, and later reinstated discontinued medication in April 2016.
Teague alleged neither doctor referred him to a qualified physician and that he remained in pain; he also made claims against Head Nurse Lynn H. for record-release conditions, charging for care, and disputes over treatment.
Court screened the amended complaint under 28 U.S.C. § 1915A, allowed Eighth Amendment deliberate-indifference claims to proceed against Drs. Hall and Tieman in their individual capacities, and dismissed all other claims and Lynn H.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether doctors’ actions amounted to Eighth Amendment deliberate indifference	Teague: doctors refused adequate treatment, failed to refer to a qualified physician, and left him in pain	Doctors: treatment decisions/disagreements do not equal constitutional violation; they were managing care and some said they were unqualified to adjust meds	Allowed: Claim proceeds against Dr. Hall and Dr. Tieman — allegations that they refused referral and that Tieman adjusted meds despite saying he was unqualified state a plausible deliberate-indifference claim
Whether a disagreement over medical judgment states an Eighth Amendment claim	Teague: his pain required different/more frequent treatment than provided	Defendants: plaintiff only disagrees with medical judgment; courts should not substitute their judgment for doctors	Denied to extent of broad disagreement: mere disagreement not actionable; but alleged substantial departure from professional judgment may be actionable here
Whether Head Nurse Lynn H. is liable for constitutional violations	Teague: Lynn refused to release records without conditions, charged for care, and argued about medications	Lynn: actions were administrative, lawful (release conditions, charging), and she did not prescribe or prevent medical access	Dismissed: nurse not alleged to have prescribed or prevented care; disputes and administrative conditions do not establish individual constitutional liability
Scope of relief and service	Teague: seeks to proceed against all named defendants for inadequate care	Defendants: (implicit) limited liability for those who made medical decisions	Court: grants leave to proceed only against Drs. Hall and Tieman; directs service and orders defendants to respond only to allowed claims

Key Cases Cited

Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints are liberally construed)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
Forbes v. Edgar, 112 F.3d 262 (7th Cir. 1997) (prisoners not entitled to demand specific or best care)
Ciarpaglini v. Saini, 352 F.3d 328 (7th Cir. 2003) (disagreement with medical professionals not a cognizable Eighth Amendment claim)
Jackson v. Kotter, 541 F.3d 688 (7th Cir. 2008) (liability requires decision that is a substantial departure from accepted professional judgment)
Snipes v. DeTella, 95 F.3d 586 (7th Cir. 1996) (court should not interfere with medical pain mitigation decisions except in extreme cases)
Poole v. Isaacs, 703 F.3d 1024 (7th Cir. 2012) (constitution does not guarantee free medical care)
Burks v. Raemisch, 555 F.3d 592 (7th Cir. 2009) (public employees responsible for their own misconduct, not others)