McCann v. Ogle County

Federal 7th Circuit Court
Civil Court
Prisoners
Citation
Case Number: 
No. 17-3139
Decision Date: 
November 30, 2018
Federal District: 
N.D. Ill., W. Div.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendants-jail personnel’s motion for summary judgment in plaintiff-decedent’s section 1983 action alleging that defendants violated his 14th Amendment rights, where plaintiff died after physician hired by jail over-prescribed methadone while plaintiff was detained and awaiting trial. Record showed that plaintiff had already settled claim against physician, and plaintiff failed to establish viable claim under objective reasonableness standard for pretrial detainees, where: (1) defendant-nurse merely administered methadone dosages pursuant to physician’s directive; and (2) nurse otherwise attended to plaintiff’s medical needs. Fact that nurse failed to take plaintiff’s vital signs on morning of his death demonstrated, at worst, act of negligence, which was insufficient  to support claim of inadequate medical care under 14th Amendment. Also, Dist. Ct. did not err in: (1) granting summary judgment filed by defendants-Sheriff and jail captain, since both individuals were not responsible for plaintiff’s medical care and took no steps to either contribute or detract from said care; and (2) granting defendant-County’s motion for summary judgment, since plaintiff failed to factually support claim that defendant made decision to house plaintiff in jail as opposed to hospital based on policy that favored cost savings over necessary medical treatment.