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Timothy Youngblood v. John Trost
20-2968
| 7th Cir. | Sep 21, 2021
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Background

  • 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)
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Case Details

Case Name: Timothy Youngblood v. John Trost
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Sep 21, 2021
Docket Number: 20-2968
Court Abbreviation: 7th Cir.