GADDIS v. CRAWFORD COUNTY SHERIFF'S DEPT.

CourtDistrict Court, S.D. Indiana
DecidedFebruary 21, 2024
Docket4:21-cv-00140
StatusUnknown

This text of GADDIS v. CRAWFORD COUNTY SHERIFF'S DEPT. (GADDIS v. CRAWFORD COUNTY SHERIFF'S DEPT.) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GADDIS v. CRAWFORD COUNTY SHERIFF'S DEPT., (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA NEW ALBANY DIVISION

DELBERT S. GADDIS, III, ) ) Plaintiff, ) ) v. ) No. 4:21-cv-00140-SEB-KMB ) CYNTHIA KEMP, ) ROY WASHINGTON, ) ) Defendants. )

ORDER DENYING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT AND DIRECTING FURTHER ACTION

Plaintiff Delbert S. Gaddis III filed this suit under 42 U.S.C. § 1983 alleging that Defendants violated his constitutional rights by failing to provide him with adequate medical care while he was incarcerated at the Crawford County Jail ("Jail"). Dkt. 57 (Order Screening Second Amended Complaint); dkt. 58 (Second Amended Complaint). Defendants have moved for summary judgment. Dkt. 101. For the reasons explained below, genuine issues of material fact exist, and the motion is denied. I. Embedded Motion to Supplement

In their summary judgment motion, Defendants argue that they provided constitutionally adequate care for three of Mr. Gaddis's medical conditions—knee pain, back pain, and high blood pressure. Dkt. 103 (brief in support of summary judgment motion). In response, Mr. Gaddis contended that genuine issues of material fact existed for trial because Defendants did not address another one of his conditions—a hand injury he suffered after punching a wall. Dkt. 104. In reply, Defendants argued: Medical Defendants did not address that issue in their Motion for Summary Judgment and specifically included a footnote to their Statement of Facts explaining that Plaintiff received medical care for other issues in the jail but that the Summary Judgment Motion was limited to the facts regarding the medical issues in this lawsuit. The Court's Screening Order, which lays out the claims Plaintiff is allowed to proceed on, did not specify any claims regarding a broken right hand. The Court's Screening Order was limited to Plaintiff's claims of inadequate treatment for his knee issue, a back issue, high blood pressure, and his desire for an MRI. Plaintiff was then given a deadline of February 18, 2022 to notify the Court if he wanted to proceed on any issues not specified by the Court's Screening Order. See Court's Docket No. 29. Plaintiff did not take that opportunity to inform the Court and the parties that his broken right hand was an issue. If the Court clarifies that Plaintiff's broken right hand is indeed part of this lawsuit, then Defendants request time to file a supplemental brief on just that issue to be considered with their Motion for Summary Judgment. Dkt. 108 at 3–4. Defendants' embedded request for time to supplement their summary judgment motion is denied. First, the request runs afoul of Southern District of Indiana Local Rule 7-1(a), which provides, "Motions must be filed separately, but alternative motions may be filed in a single document if each is named in the title. A motion must not be contained within a brief, response, or reply to a previously filed motion, unless ordered by the court." S.D. Ind. L. R. 7-1(a) (emphasis added). Second, even if Defendants had properly filed a motion, the Court would deny it. The summary judgment deadline had already passed when Defendants asked for time to add new arguments to their summary judgment brief. To grant the request to effectively extend the summary judgment deadline so that Defendants could brief the hand injury, the Court would have to find excusable neglect for their failure to address the right-hand injury in their original summary judgment briefing. Fed. R. Civ. P. 6(b)(1)(B); Bowman v. Korte, 962 F.3d 995, 997–99 (7th Cir. 2020) (finding that district court abused its discretion in allowing defendants to file untimely summary judgment motion without finding excusable neglect under Rule 6(b)(1)(B)). To find "excusable neglect," courts should consider all relevant circumstances surrounding the party's neglect, including the prejudice to the non-movant, length of delay, and reason for delay. Id. at 998.

Defendants haven't shown that their failure to address the right-hand injury was caused by excusable neglect. Instead, they effectively blame the Court and Mr. Gaddis for their omission— arguing that the Court didn't mention the hand injury in its Screening Order and that Mr. Gaddis failed to inform the Court of that omission. It is certainly true that the Court did not address the hand issue in the Screening Order discussed in Defendants' reply, but Defendants' reply fails to mention that—after that Screening Order was issued—the Court allowed Mr. Gaddis to file a second amended complaint and screened it. Dkt. 57. That second Screening Order specifically mentioned the hand injury when it summarized the basis for Mr. Gaddis's claims: On October 7, 2021, Mr. Gaddis was sent to the emergency room for pain and swelling in his hands after he punched a wall. He was diagnosed with a bone fracture in his right hand. He was given ice for swelling and told to see an orthopedic doctor within a week. His hand was not splinted or put into a cast. After his return to the Jail, Mr. Gaddis only received ice, and he never was sent to the orthopedic doctor. Nurse Practitioner Washington never examined Mr. Gaddis but simply overrode the emergency doctor's order and decided that Mr. Gaddis should not see an outside specialist. Id. at 4. Defendants' counsel certainly knew about the second amended complaint—and presumably the second Screening Order—because they answered the second amended complaint the day after the second Screening Order was docketed. Dkt. 59. Defendants' counsel also received a copy of the second Screening Order via the Court's CM/ECF system. Dkt. 57. The Court will not speculate as to why Defendants' reply fails to acknowledge the existence of the second amended complaint and the second Screening Order. Perhaps some neglect contributed to Defendants' failure to address the hand injury in their original summary judgment motion and their failure to mention the second Screening Order in their reply, but Rule 6(b) requires more than ordinary neglect—it requires excusable neglect. Bowman, 962 F.3d at 998. And Defendants haven't shown that any neglect here was excusable. The delay was significant—

Defendants didn't ask for time to supplement until two months after the summary judgment deadline. And the potential for prejudice to Mr. Gaddis is plain because he explained why fact issues existed as to the adequacy of the treatment for his hand in his response, which would allow Defendants to tailor their new arguments to that explanation. Regardless, even if there were no prejudice, the fact remains that Defendants have not offered a legitimate reason for failing to address the right-hand injury in their opening motion, which is fatal to their request. Id. (defendants' failure to explain counsel's oversight is fatal under Rule 6(b)).1 Defendants also have not explained why they could not have at least briefed the issues related to the right-hand injury in their reply brief, which they were given additional time to file. See dkt. 107. For all of these reasons, the Court denies Defendants' request for leave to supplement their

summary judgment motion to address the treatment of Mr. Gaddis's right-hand injury. II. Legal Standard A motion for summary judgment asks the Court to find that a trial is unnecessary because there is no genuine dispute as to any material fact and, instead, the movant is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a).

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Bluebook (online)
GADDIS v. CRAWFORD COUNTY SHERIFF'S DEPT., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gaddis-v-crawford-county-sheriffs-dept-insd-2024.