Summary
In *Palmer v. Franz*, 928 F.3d 560 (7th Cir. 2019), the Seventh Circuit held that an inmate’s congenital missing hand constituted an objectively serious medical condition requiring an accommodation (a low bunk permit) under the Eighth Amendment. The court reversed summary judgment for a nurse who, despite being aware of the inmate’s deformity and explicit request for a low bunk, took no steps to mitigate the known risk of harm. The decision clarifies that deliberate indifference may be found where a prison official fails to act in the face of an obvious risk, and that a physical disability requiring accommodation rather than traditional treatment can satisfy the objective component of an Eighth Amendment deliberate-indifference claim.
Topics
Practice areas
Questions Presented
- Whether the district court erred in granting summary judgment on the Eighth Amendment deliberate indifference claim.
Holdings
- A reasonable jury could conclude that Palmer's deformity was an objectively serious medical condition requiring accommodation and that Franz was deliberately indifferent by failing to act.
Key quotations
“An objectively serious medical condition is one that has been diagnosed by a physician as mandating treatment or one that is so obvious that even a lay person would perceive the need for a doctor’s attention.” (562)
“Summary judgment is appropriate if there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law.” (564)
Factual background
Palmer, an inmate with a missing left hand, had a low bunk pass at Shawnee. Upon transfer to NRC, Franz conducted intake and noted the deformity but ignored Palmer's request for a low bunk pass. Palmer was assigned a top bunk and fell, injuring his knee.
Procedural history
Palmer filed a complaint alleging Eighth Amendment deliberate indifference and negligence. The district court granted summary judgment to Franz on the Eighth Amendment claim and dismissed the negligence claim without prejudice. Palmer appealed.
Remand instructions
Further proceedings consistent with the opinion.