District Court Grants Summary Judgment in Nurses’ Favor on Inmate’s Claims of Sporadic Headaches and Blurry Vision

January 17, 2018

Judge Sara Darrow in the Central District of Illinois granted summary judgment in favor of two nurses at the Vermilion County Jail in Danville, Illinois in Johnson v. Galloway, et al. Case No. 16-CV-02096 (C.D. Ill. Jan. 8, 2018). Plaintiff, a pre-trial detainee, alleged that two nurses at the Vermilion County Jail were deliberately indifferent to his claims that he had sporadic headaches and blurry vision after being tased during his arrest. Plaintiff was examined by the nursing staff five days after he arrived to the facility. Plaintiff requested an MRI or CT scan, but the nurses determined that it was not necessary due to the lack of visible injuries and his complaint of merely sporadic headaches. Plaintiff submitted another medical request regarding his headaches, and he was provided with a prescription for ibuprofen and the nurses examined him, noting no deterioration of his condition. Plaintiff alleged that he submitted two additional medical requests related to his headaches, but both nurses denied knowledge of the additional medical requests. Plaintiff was then transferred to the DeWitt County Jail. While at the DeWitt County Jail, Plaintiff was examined, no evidence of any injury was found, and he was prescribed ibuprofen for his headaches.

Judge Darrow found that Plaintiff’s medical conditions – sporadic headaches and blurry vision – were not objectively serious enough to warrant liability based on the treatment he received for his complaints. Further, Plaintiff could not establish that the step taken to address his condition – prescribing ibuprofen – was unreasonable. Finally, Plaintiff could not establish that the actions taken by the nurses were in conscious disregard of any risk to his safety. The nurses were represented by Michael Condon and Tony Fioretti.

Johnson v Galloway

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