Moore v. Grant County Jail

District Court, N.D. Indiana·Decided October 3, 2024·No. 1:24-cv-00333·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

JOSHUA LAMAR MOORE,

Plaintiff,

v. CAUSE NO. 1:24-CV-333-HAB-SLC

CHILDS, LORI BYRD, and GRANT COUNTY SHERIFF,

Defendants.

OPINION AND ORDER Joshua Lamar Moore, a prisoner without a lawyer who goes by Joshua Davis, filed a motion for a preliminary injunction. ECF 3. The Grant County Sheriff has responded, and Davis has replied. ECF 27, 21, 22. The motion is ready to be decided. I. Legal Standard “[A] preliminary injunction is an extraordinary and drastic remedy, one that should not be granted unless the movant, by a clear showing, carries the burden of persuasion.” Mazurek v. Armstrong, 520 U.S. 968, 972 (1997) (emphasis in original). “A plaintiff seeking a preliminary injunction must establish that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). On the first prong, “the applicant need not show that [he] definitely will win the case.” Illinois Republican Party v. Pritzker, 973 F.3d 760, 763 (7th Cir. 2020). However, “a mere possibility of success is not enough.” Id. at 762. “A strong showing . . . normally includes a demonstration of how the applicant proposes to prove the key elements of its

case.” Id. at 763 (quotation marks omitted). In assessing the merits, the court does not simply “accept [the plaintiff’s] allegations as true” or “give him the benefit of all reasonable inferences in his favor, as would be the case in evaluating a motion to dismiss on the pleadings.” Doe v. Univ. of S. Indiana, 43 F.4th 784, 791 (7th Cir. 2022). Instead, the court must make an assessment of the merits as “they are likely to be decided after more complete discovery and litigation.” Id.

On the second prong, “[i]ssuing a preliminary injunction based only on a possibility of irreparable harm is inconsistent with . . . injunctive relief as an extraordinary remedy that may only be awarded upon a clear showing that the plaintiff is entitled to such relief.” Winter, 555 U.S. at 22. Mandatory preliminary injunctions— those “requiring an affirmative act by the defendant”—are “cautiously viewed and

sparingly issued.” Mays v. Dart, 974 F.3d 810, 818 (7th Cir. 2020). Additionally, in the prison context, the court’s ability to grant injunctive relief is limited. “[I]njunctive relief to remedy unconstitutional prison conditions must be narrowly drawn, extend no further than necessary to remedy the constitutional violation, and use the least intrusive means to correct the violation of the federal right.” Westefer v. Neal, 682 F.3d 679, 681

(7th Cir. 2012) (citation and internal quotation marks omitted); see also Rasho v. Jeffreys, 22 F.4th 703, 711-13 (7th Cir. 2022) (outlining strict limitations on granting injunctive relief in correctional setting). As outlined in the screening order, Davis alleges he is not getting adequate medical care at the Grant County Jail for a pre-existing shoulder injury. ECF 6. He

claims that at the time he entered the jail, he was under the care of a doctor for a shoulder injury and needed surgery. He further claims he was not allowed to wear the arm brace he was using when he entered the jail. And, finally, he alleges he should have been housed in the medical ward, not general population. He is proceeding on a claim for damages against Lori Byrd, who made the treatment decisions at issue, and against the Grant County Sheriff for prospective injunctive relief related to his medical care. He

is also proceeding on a claim against Detention Deputy Childs on a claim for failing to protect him from an attack that is unrelated to the matters at issue in this preliminary injunction motion. Pretrial detainees are entitled to constitutionally adequate medical care under the Fourteenth Amendment, which requires jail staff to take “reasonable available

measures” to address a “risk of serious harm” to their health or safety. Pittman v. Madison Cnty., 108 F.4th 561, 572 (7th Cir. 2024). Whether a plaintiff is being provided reasonable care is determined by a purely objective standard. Id. The reasonableness of the care provided is assessed based on whether “reasonable officers under the circumstances would have understood the high degree of risk involved, making the

consequences of the defendants’ conduct obvious.” Id. (emphasis omitted). Action or inaction can be unreasonable if that decision is “not rationally related to a legitimate governmental objective” or is “excessive in relation to that purpose.” Kingsley v. Hendrickson, 576 U.S. 389, 398 (2015). “Reasonableness, in turn, must be determined in light of the totality of the circumstances.” Pulera v. Sarzant, 966 F.3d 540, 550 (7th Cir. 2020). “[L]iability for negligently inflicted harm is categorically beneath the threshold of

constitutional due process.” Kingsley, 576 U.S. at 396 (quotation marks omitted). II. Facts The Sheriff addresses two particular areas of Davis’ care at the jail: (1) the care he is receiving for his shoulder injury, including his request to wear his arm in a sling, and (2) whether Davis is appropriately housed in general population and not a medical block. ECF 17 at 1. The Sheriff argues that preliminary injunctive relief is not warranted

and has submitted medical and other records in support. A. Medical Care for Shoulder Injury The record reflects that when Davis entered the Grant County Jail on January 17, 2024, he had been under the care of a doctor for the past five months for a shoulder injury following a car accident. ECF 1-3 at 1. Davis had completed physical therapy and

received an injection in his shoulder, but pain persisted. Id. At this point, Davis was prescribed the muscle relaxant cyclobenzaprine and the NSAID meloxicam, and the doctor recommended that he have an MRI on his shoulder. Id. But less than a week later, Davis was arrested and booked into the jail. ECF 17-1 at 1. At booking on January 17, 2024, jail staff completed a medical screening. ECF 17-

1 at 3-4. In that screening, Davis stated that his arm was broken and that he brought the medication cyclobenzaprine with him. Id. at 3. But he responded “no” to the question whether he needed medical attention right now. Id. at 4. In the Initial Health Assessment, it was noted that they received records from Fort Wayne Ortho regarding a displaced fracture of his right shoulder that had healed routinely. ECF 17-5 at 2. The assessment noted the next step in Davis’ treatment was to have an MRI with possible

surgical intervention, but the MRI did not happen because of Davis’ arrest. Id. The initial plan of care at the jail was to continue Davis on the NSAID meloxicam and for him to follow up with his ortho upon release. Id. On March 12, 2024, Davis was seen at sick call due to complaints of right shoulder pain. ECF 17-7 at 16.

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