Summary Judgment Granted When Jail Provided Inmate With Reasonable Medical Care

February 20, 2023

On February 7, 2023, Federal Judge Colin Bruce granted summary judgment in favor of Kankakee County and numerous County officials. The County and its officials were sued last year by an inmate who was claiming that he did not receive medical care during a brief (11 day) stint in the County Jail in February 2022.  Specifically, the inmate claimed that he had not received all of his medications for his various physical and mental health conditions (i.e., hypertension, bipolar disorder, anxiety, schizophrenia) and that he did not have constant access to his CPAP machine which he used at times to treat another one of his medical conditions, sleep apnea.

In considering the inmate’s claims, the court observed that medical care claims brought by pretrial detainees under the Fourth Amendment are now subject only to an “objective unreasonableness” standard, which is somewhat less onerous than the Fourteenth Amendment’s standard which requires that an inmate must plead and prove that a correctional official acted with “deliberate indifference” to a serious medical condition.

Under the Fourteenth Amendment standard, an inmate must show that correctional officials acted “purposefully, knowingly or perhaps even recklessly.”  Additionally, an inmate must show that an official’s conduct was objectively unreasonable.  Under this test, an inmate must show that officials were “more than negligent” with the standard being “something akin to reckless disregard” towards an inmate’s serious medical needs.  Still, an inmate can defeat summary judgment by showing that an official’s response was “so inadequate that . . . no minimally competent professional would have responded” the way that he did.

In the instant case, however, Judge Bruce observed that the inmate had been given his various medications from officials after the medications had been verified by the inmate’s local pharmacist.  The court also noted that the inmate had been given access to his CPAP machine after his wife had brought it to the jail and that the inmate had received other medical care and mental health treatment during his brief stint at the jail.  Of note, the inmate conceded at his deposition that he had not even been using his CPAP machine immediately before being taken into custody, admitting that he had been abusing drugs in the days just before his arrest.  Given these facts, the court had little difficulty entering summary judgment in favor of the County and its officials.  The County and its officials were represented in the case by Michael Condon, Jason Rose and Christian Ketter.

Sampson v. Downey, et al.

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