Summary
This Seventh Circuit opinion reviews a district court's grant of summary judgment in favor of a state corrections official sued in her individual capacity for an Eighth Amendment deliberate indifference claim. The plaintiff, representing the estate of an inmate who died from Hepatitis C complications, alleged that the official's policy of rationing direct-acting antivirals based on disease severity caused the death. The appellate court affirmed, finding insufficient evidence that the official personally acted with deliberate indifference or that her specific actions directly caused the inmate's preventable death.
Topics
Practice areas
Questions Presented
- Whether Dr. Dauss acted with deliberate indifference to an inmate’s serious medical condition under the Eighth Amendment.
Holdings
- The court affirmed the district court’s summary judgment, finding insufficient evidence that Dr. Dauss was deliberately indifferent to Mr. Tackett’s condition.
Key quotations
“"Summary judgment is appropriate when there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law."” (at *15)
“"The Eighth Amendment’s ban on cruel and unusual punishment makes a prison official liable for acting with deliberate indifference to an inmate’s serious medical need."” (at *15)
Factual background
Inmate Raymond Tackett died in 2019 from complications of chronic Hepatitis C after the Indiana Department of Corrections failed to provide him direct‑acting antivirals (DAAs) despite his eligibility under the prison's priority policy. His daughter, Skyler Tackett, sued Dr. Kristen Dauss, the IDOC chief medical officer, alleging deliberate indifference under the Eighth Amendment.
Procedural history
The district court granted summary judgment in favor of Dr. Dauss, finding she took reasonable steps to expand access to DAAs and was not responsible for the medical decisions that led to Mr. Tackett's death. The plaintiff appealed.