Daniel v. Cook County

Dist. Ct. erred in granting defendants-prison officials’ motion for summary judgment in plaintiff-pre-trial detainee’s section 1983 action alleging that defendants were deliberately indifferent to his medical needs with respect to providing delayed treatment for his wrist injury. Dist. Ct. erred in finding that 2008 report authored by U.S. Dept. of Justice regarding its investigation of health care provided by defendants’ Jail was not admissible to prove truth of its findings, since said report was admissible under hearsay exception for civil cases under section 803(8)(A)(iii). Moreover, plaintiff himself proffered sufficient evidence to raise genuine issue of material fact as to whether his injury resulted from systemic gross deficiencies in Jail’s medical care, where plaintiff and Jail staff testified about systemic problems with health care scheduling and recordkeeping that resulted in extensive delay in treatment of plaintiff’s wrist injury. Ct. rejected defendant-Sheriff’s argument that he could not be liable for plaintiff’s injuries since Sheriff’s Dept. was not responsible for plaintiff’s medical care, since Ct. found that there was close relationship between Sheriff’s Dept. and entity providing medical services.