Timothy Youngblood v. John Trost
20-2968
| 7th Cir. | Sep 21, 2021Background
- Timothy Youngblood, an Illinois inmate, was diagnosed with a right groin hernia in 2013 and later developed a left groin hernia; he sought surgical repair for both.
- From 2013–2016 medical staff frequently described the hernias as reducible and treated him with conservative measures (hernia belt, laxatives, pain medication), which Youngblood often refused; records sometimes noted no apparent distress.
- Menard/Wexford medical staff referred Youngblood to an outside surgeon; the right hernia was recommended for surgery and repaired in April 2017; the left hernia was later repaired in October 2018 after becoming painful and non-reducible.
- Youngblood filed grievances claiming Wexford pressured doctors to deny/delay surgery for reducible but painful hernias to cut costs and sued Wexford, the Menard medical director, a grievance administrator, and the warden under 42 U.S.C. § 1983 for Eighth Amendment violations.
- The district court granted summary judgment for defendants; the Seventh Circuit affirmed, finding no evidence of an unconstitutional Wexford policy or of deliberate indifference that caused Youngblood’s delayed surgeries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal/contractor liability (policy or widespread practice) | Wexford encouraged denying/delaying surgery for reducible, painful hernias to save money | No policy/practice exists; Wexford doctors approved Youngblood’s surgeries even when reducible | No evidence of unconstitutional Wexford policy; summary judgment for defendants |
| Causation/harm from alleged policy | Policy caused needless delay and pain for Youngblood | Delay was due to medical judgment and conservative treatment; not a Wexford cost-cutting policy | Even assuming such a policy, record shows it did not cause Youngblood’s harm |
| Individual deliberate indifference (medical director, grievance admin) | Officials ignored or were indifferent to need for left‑side surgery | Medical director reasonably relied on outside surgeon; administrator relied on medical unit info | Medical director and administrator entitled to summary judgment |
| Injunctive relief against warden | Requested relief to secure timely care | No actionable policy or ongoing harm shown | No injunction warranted; summary judgment for warden |
Key Cases Cited
- Glisson v. Indiana Dep’t of Corr., 849 F.3d 372 (7th Cir. 2017) (en banc) (prison-contractor liability requires unconstitutional policy or practice)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (U.S. 1978) (municipal liability for unconstitutional policy or custom)
- Ray v. Wexford Health Sources, Inc., 706 F.3d 864 (7th Cir. 2013) (no relief where alleged policy caused no harm to plaintiff)
- Pyles v. Fahim, 771 F.3d 403 (7th Cir. 2014) (prisoners are not entitled to preferred course of treatment)
- Thomas v. Martija, 991 F.3d 763 (7th Cir. 2021) (physician entitled to rely on peer opinions; summary judgment appropriate where treatment was reasonable)
- Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (non-medical officials may defer to medical judgment)
- Hayes v. Snyder, 546 F.3d 516 (7th Cir. 2008) (administrators not liable for mistaken reliance on medical unit information)
