Allison v. Hughes

CourtDistrict Court, C.D. Illinois
DecidedJuly 11, 2024
Docket3:23-cv-03224
StatusUnknown

This text of Allison v. Hughes (Allison v. Hughes) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allison v. Hughes, (C.D. Ill. 2024).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

ROBERT W. ALLISON, ) ) Plaintiff, ) ) v. ) 23-cv-3224 ) LATOYA HUGHES, et al. ) ) Defendants. )

ORDER Plaintiff, proceeding pro se and presently incarcerated at Murphysboro Life Skills Re-Entry Center, alleges Defendants violated his Eighth Amendment rights through deliberate indifference to his serious medical needs while he was incarcerated at Graham Correctional Center. The Court initially dismissed the complaint for failure to adequately plead a federal claim. Plaintiff filed a timely amended complaint. A. Motion to Request Counsel Plaintiff’s Motion to Request Counsel (Doc. 13) is before the Court. The Court undertakes a two-part inquiry: (1) whether the plaintiff made a reasonable attempt to obtain counsel or has been effectively precluded from doing so, and, if so, (2) given the difficulty of the case, does the plaintiff appear competent to litigate it himself. Pruitt v. Mote, 503 F.3d 647, 655 (7th Cir 2007). The second step can be hard to assess. The Court must consider the factual and legal difficulty of a plaintiff’s claims, and the plaintiff’s competence to litigate them, while accounting for the plaintiff’s literacy, communication skills, educational level, and litigation experience, plus the plaintiff’s intellectual capacity and psychological history (if information on those topics is before the court). Watts v. Kidman, 42 F.4th 755, 760

(7th Cir. 2022). Plaintiff has now shown a reasonable, though unsuccessful, attempt to secure counsel on his own behalf. The Court thus considers Plaintiff’s ability to represent himself. The factual difficulty of Plaintiff’s medical care-related claims is mixed. Plaintiff is aware of some facts personally, and others are solely within the knowledge of his

healthcare providers. Much of the evidence is contained in his medical records. The legal difficulty of Plaintiff’s claim is certainly challenging. Proving deliberate indifference to a serious medical need requires proving the mental state of the defendants, and that is a high bar to meet. However, nearly all plaintiffs filing lawsuits like Plaintiff’s ask for a volunteer lawyer. There is no right to a lawyer in a civil action,

and the demand greatly exceeds the number of lawyers willing to take on such cases. While a lawyer would certainly help Plaintiff, his claim is not so atypically difficult that this factor weighs heavily toward granting Plaintiff’s motion. Plaintiff is a high school graduate and his pleadings are clearly written. He does not indicate any difficulty with the English language. He does not identify any

psychological or intellectual capacity impairments. It also does not appear that he has any litigation experience. The Court finds Plaintiff is able to represent himself. His pleadings are of decent quality and although he certainly faces difficulty in prosecuting this lawsuit, federal litigation is inherently difficult and that reality is not unique to Plaintiff. The motion is denied. B. Merit Review

The Court must “screen” Plaintiff’s amended complaint, and through such process identify and dismiss any legally insufficient claim, or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id.

The court accepts the factual allegations as true, liberally construing them in the plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (7th Cir. 2013). Conclusory statements and labels are insufficient—the facts alleged must “state a claim for relief that is plausible on its face.” Alexander v. United States, 721 F.3d 418, 422 (7th Cir. 2013) (citation omitted).

Defendants. Plaintiff’s amended complaint names only Illinois Department of Corrections Director Latoya Hughes and prison healthcare contractor Wexford Health Sources, Inc. Plaintiff omits all the individual Defendants named in his original complaint. Factual allegations. On April 8, 2022, Plaintiff entered Graham Correctional Center. Upon entry Plaintiff suffered from 1) Chronic Obstructive Pulmonary Disease

(COPD) and 2) skeletal fractures of his pelvis and hips sustained former in vehicle accidents, for which he had received orthopedic surgery prior to imprisonment. While incarcerated Plaintiff suffered a third injury, a broken finger. Plaintiff asserts he received constitutionally inadequate medical care for each of these three medical conditions.

Legal standard. Deliberate indifference to a serious medical need is actionable as a violation of the Eighth Amendment. Hayes v. Snyder, 546 F.3d 516, 522 (7th Cir. 2008). Deliberate indifference is proven by demonstrating that a prison official knows of a substantial risk of harm to an inmate and “either acts or fails to act in disregard of that risk.” Arnett v. Webster, 658 F.3d 742, 751 (7th Cir. 2011). A claim does not rise to the level of an Eighth Amendment issue, however, unless the inadequate medical care is

“deliberate or otherwise reckless in the criminal law sense, which means that the defendant must have committed an act so dangerous that his knowledge of the risk can be inferred or that the defendant actually knew of an impending harm easily preventable.” Antonelli v. Sheahan, 81 F.3d 1422, 1427 (7th Cir. 1996); see also Pyles v. Fahim, 771 F.3d 403, 411-12 (7th Cir. 2014) (healthcare providers may exercise their

medical judgment when deciding whether to refer a prisoner to a specialist). The failure to refer constitutes deliberate indifference only if it was “blatantly inappropriate.” Id. at 411-12. Denying or delaying a referral in favor of “easier and less efficacious treatment” may be blatantly inappropriate if it does not reflect an exercise of sound professional

judgment. Petties v. Carter, 836 F.3d 722, 729-30 (7th Cir. 2016), as amended (Aug. 25, 2016). Although a prisoner may disagree with a doctor’s choice of medication and would like a stronger medication, prison officials “have strong incentives to limit the provision of controlled substances [such as opioid medication] to inmates for medical care; these drugs carry a high risk of being abused or distributed to others.” Knox v.

Shearing, 637 F. App’x 226, 228–29 (7th Cir. 2016); see also Snipes v. DeTella, 95 F.3d 586, 591 (7th Cir. 1996) (“What we have here is not deliberate indifference to a serious medical need, but a deliberate decision by a doctor to treat a medical need in a particular manner.”). The Court’s prior order. In the Court’s initial Merit Review Order (Doc. 12), the Court found Plaintiff had failed to state a claim and dismissed the complaint with leave

to replead.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Arnett v. Webster
658 F.3d 742 (Seventh Circuit, 2011)
Michael C. Antonelli v. Michael F. Sheahan
81 F.3d 1422 (Seventh Circuit, 1996)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Hayes v. Snyder
546 F.3d 516 (Seventh Circuit, 2008)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Christopher Pyles v. Magid Fahim
771 F.3d 403 (Seventh Circuit, 2014)
Vandaire Knox v. Robert Shearing
637 F. App'x 226 (Seventh Circuit, 2016)
Tyrone Petties v. Imhotep Carter
836 F.3d 722 (Seventh Circuit, 2016)
Ashoor Rasho v. Willard Elyea
856 F.3d 469 (Seventh Circuit, 2017)
William Watts v. Mark Kidman
42 F.4th 755 (Seventh Circuit, 2022)
Sarah Thomas v. Neenah Joint School District
74 F.4th 521 (Seventh Circuit, 2023)

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