Hare v. Tharp

District Court, S.D. Illinois·Decided August 18, 2023·No. 3:22-cv-02281·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

KEITH L. HARE, #Y50064, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-02281-JPG ) KRISTOPHER THARP, ) ROCHELLE BRAUN, ) and MARY DAMBACHER, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Now before the Court is an Amended Complaint filed by Plaintiff Keith Hare. (Doc. 14). Plaintiff brings this civil rights action pursuant to 42 U.S.C. § 1983 for constitutional deprivations that occurred during his confinement at Madison County Jail (“Jail”) in Edwardsville, Illinois, (Id. at 1-66). Plaintiff claims that these individuals denied him medical care for serious health conditions from December 3, 2019 to February 13, 2022. He seeks monetary relief. The First Amended Complaint is now before the Court for review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of the complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). First Amended Complaint Plaintiff sets forth the following allegations in the Amended Complaint (Doc. 14, pp. 9- 21): While housed at Madison County Jail from December 3, 2019 until February 13, 2022, Plaintiff suffered from several serious medical conditions, including left shoulder pain,1 a heart condition,2 abnormal bloodwork,3 and exposure to COVID-19.4 Id. at 9. He alleges that Defendants Tharp, Braun, and Dambacher either denied medical care for these conditions or allowed others to deny him care. Id. at 10.

Plaintiff sets forth the following claims against Defendants in the First Amended Complaint: Count 1: Eighth or Fourteenth Amendment claim against Defendants Braun and Tharp for denying Plaintiff adequate medical care for his left shoulder, elbow, and hand pain from June 2020 until February 2022.

Count 2: Eighth or Fourteenth Amendment claim against Defendants Braun and Dambacher for denying Plaintiff adequate medical care for his heart condition, i.e., cardiomyopathy, from June 2020 until February 2022.

Count 3: Eighth or Fourteenth Amendment claim against Defendant Braun for denying Plaintiff adequate medical care following his abnormal bloodwork.

Count 4: Fourteenth Amendment claim against Defendants Braun and Dambacher for denying Plaintiff adequate medical care for COVID-19 in October 2020.

Count 5: Eighth or Fourteenth Amendment claim against Defendants for failing to send a copy of his medical records with him when he transferred into the custody of the Illinois Department of Corrections.

Any other claim not addressed herein is dismissed without prejudice as inadequately pled.5

1 Plaintiff explains that his left shoulder pain progressively worsened, until he lost the ability to raise his left arm above his head or make a fist. He was sent to an outside provider, who recommended additional bloodwork, tests, and surgery. These recommendations were disregarded. (Id. at 11-12). 2 Plaintiff was sent for emergency room treatment of chest pain twice before being referred to a specialist, who diagnosed him with cardiomyopathy and gave him a heart monitor to wear for three days. Plaintiff was denied review of the results or further care for his condition. (Id. at 13-16). 3 Plaintiff lists the following concerns about his abnormal bloodwork, among others: Vitamin D deficiency, “Hep B Core Ab” (positive abnormal), antinuclear antibodies (positive abnormal), and homogenous pattern (high). He identifies the “suggested disease association” as lupus, scleroderma, or primary biliary cirrhosis (liver damage). (Id. at 16-19). 4 Plaintiff contracted COVID-19 during his pretrial detention in October 2020. He alleges that no one monitored the severe effects of his illness or sent him to a hospital for treatment. (Id. at 19-21). 5 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face”). Discussion The applicable legal standard for these claims is derived from Plaintiff’s status as a pretrial detainee or convicted prisoner at the time each claim arose. Plaintiff indicates that he was a pretrial detainee until November 17, 2021 and a convicted prisoner from November 17, 2021 until his

transfer in February 13, 2022. Because his claims arose during both time periods, the Court will review both legal standards applicable to his claims. The Court previously explained that a pretrial detainee’s claim for the denial of medical care is governed by the Fourteenth Amendment Due Process Clause. When presented with this claim, the Court first considers whether “defendants acted purposefully, knowingly, or perhaps even recklessly when they considered the consequences of their handling” of the detainee’s serious medical need. McCann v. Ogle Cty., Illinois, 909 F.3d 881, 886 (7th Cir. 2018) (internal quotations omitted). The Court next asks “whether the challenged conduct was objectively reasonable” based on “the totality of the facts and circumstances faced by the individual alleged to have provided inadequate medical care” to the detainee. Id. Negligence does not satisfy this standard. Id.

In contrast, a convicted prisoner’s claim for denial of medical care is subject to the Eighth Amendment prohibition against cruel and unusual punishment. Estelle v. Gamble, 429 U.S. 97, 104 (1976). When presented with a prisoner’s claim, the Court first determines whether the prisoner has described an objectively serious medical need. Id. The Court next considers whether each individual defendant responded to the prisoner’s serious medical need with deliberate indifference. Id. Negligence does not satisfy this standard either. Id. Counts 1, 2, 3, and 4 survive screening against those defendants identified in connection with each claim above, as follows: Count 1 shall proceed under the Eighth and Fourteenth Amendment against Defendants Braun and Tharp; Counts 2 shall proceed under the Eighth and Fourteenth Amendment against Defendants Braun and Dambacher; Count 3 shall proceed under the Eighth and Fourteenth Amendment against Defendant Braun; and Count 4 shall proceed under the Fourteenth Amendment, only, against Defendants Braun and Dambacher. These claims shall be dismissed without prejudice against those individual defendants who are not identified in

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Valerie McCann v. Ogle County, Illinois
909 F.3d 881 (Seventh Circuit, 2018)