Summary
The Seventh Circuit affirmed summary judgment for Milwaukee County in Calvin Lee’s § 1983 action concerning alleged inadequate medical care, excessive lockdowns, and unsanitary conditions at the Milwaukee County Jail. The court held that Lee had not presented sufficient evidence to create a triable issue regarding an underlying constitutional violation or, for certain claims, a municipal policy or practice under Monell. The court also rejected the County’s argument that it could avoid potential liability merely by contracting out medical services, but concluded that Lee’s medical-care evidence was insufficient on summary judgment.
Topics
Practice areas
Questions Presented
- Whether Lee presented sufficient evidence to create a genuine dispute that the medical and mental-health care provided at the Jail was objectively unreasonable and caused constitutional injury.
- Whether Milwaukee County could avoid Monell liability by asserting that it lacked notice of deficiencies in care provided by its private medical contractor.
- Whether the Jail's COVID-related and later lockdowns were punitive or excessive in relation to legitimate governmental objectives under the Fourteenth Amendment.
- Whether the alleged unsanitary conditions, including fecal matter, clogged sinks, blood draws near food-service areas, mold, and prolonged toilet shutoffs, constituted a constitutional deprivation attributable to the County under Monell.
Holdings
- A county cannot shield itself from potential 42 U.S.C. § 1983 liability merely by contracting out its duty to provide medical services. When a county delegates final decision-making authority to a private medical contractor, the contractor's qualifying policy may be attributable to the county.
- A pretrial detainee opposing summary judgment on a medical-care claim must present specific, admissible evidence creating a genuine dispute that the care provided was objectively unreasonable in light of a serious risk of harm and that the detainee was harmed as a result. Lee did not meet that burden.
- Lockdowns violate the Fourteenth Amendment when they are not reasonably related to a legitimate governmental objective or are excessive in relation to that objective. The lockdowns challenged by Lee were not shown to be constitutionally excessive, and the isolated later lockdowns were not sufficiently linked to a municipal policy or pervasive practice for Monell purposes.
- Lee failed to present sufficient evidence that the alleged unsanitary conditions, individually or in combination, deprived him of a constitutional right or were attributable to a widespread municipal practice under Monell.
Key quotations
“The County cannot shield itself from § 1983 liability by contracting out its duty to provide medical services.” (at 8–9)
“Even if Wellpath’s long-term therapy policy is read to set the stage for a constitutional violation, we lack a sufficient basis to conclude that one may have occurred here.” (at 12–13)
“The Fourteenth Amendment’s requirements should not be confused with “a court’s idea of how best to operate a detention facility.”” (at 13)
Factual background
Lee was a pretrial detainee at the Milwaukee County Jail from December 2020 through April 2023. He reported a history of traumatic brain injury, post-traumatic stress disorder, anxiety, depression, insomnia, headaches, blackouts, and nerve pain, but the record contained few medical records and little evidence concerning the severity of his conditions or treatment before and during detention. He complained about limited mental-health services, prolonged COVID-related lockdowns, toilet shutoffs, and various unsanitary conditions. The County contracted with Wellpath, LLC to provide medical and mental-health services, and the record was ambiguous regarding the mental-health care Lee actually received.
Procedural history
Lee filed a pro se action against Milwaukee County in September 2022. The district court screened the complaint and allowed claims under 42 U.S.C. § 1983 to proceed; after the parties consented to magistrate-judge jurisdiction, the magistrate judge granted the County's motion for summary judgment in May 2024 and dismissed the case. The Seventh Circuit appointed counsel for Lee on appeal and affirmed.