Court Rules Jail Medical Staff Did Not Act With Deliberate Indifference

October 17, 2017

Judge James Shadid of the U.S. District Court of Central Illinois granted summary judgment in favor of the county jail medical staff at Jerome Combs Detention Center (“JCDC”) in Taylor v. Huffines, et al., No. 16-cv-2100. Inmate Travis Taylor claimed that his constitutional rights were violated when the staff acted with deliberate indifference to his serious medical needs in violation of his Fourteenth Amendment rights while incarcerated at the JCDC.

Taylor was detained at the JCDC since September 16, 2015. On September 29, 2015, a nurse administered a tuberculosis shot to Taylor during his initial health evaluation and assessment at JCDC. During this appointment, Taylor told the nurse that he was experiencing rectal bleeding.  In accordance with JCDC policy, the nurse directed Taylor to fill out and submit a medical request form in order to obtain treatment for his condition. On October 1, 2015, Taylor allegedly filled out the form, but it was never submitted or received by the medical department. On October 7, 2015, Taylor submitted a second medical request form. The nurse responded the next day, informing Taylor that he was “scheduled” to see medical. On October 21, 2015, Taylor was examined by the physician’s assistant, was diagnosed with a small uncomplicated external hemorrhoid, and given treatment.

Taylor argued that the delay (from September 29 to October 21) caused unnecessary pain and demonstrated that the medical staff was deliberately indifferent to his needs. Judge Shadid disagreed, finding no evidence that the jail nurses acted on any basis other than JCDC’s policy which requires an inmate to fill out and submit a medical request in order to be examined. Taylor’s suit did not challenge the policy. Additionally, Taylor presented no evidence that the physician’s assistant knew of Taylor’s condition prior to examining Taylor on October 21, 2015. Lastly, the Court recognized that there was no evidence that Taylor’s condition was an emergency requiring immediate medical attention. Michael Condon and Tara Grimm represented the JCDC medical staff.

Taylor v. Huffines

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