Phillip Anglin v. Lisa Draper et al.

United States District Court for the Central District of Illinois, Peoria Division · December 10, 2025 · No. 1:24-cv-01424-JEH

Summary

The court denied Defendant Zia Samad’s motion for summary judgment in a Fourteenth Amendment medical-care claim brought by pretrial detainee Phillip Anglin. The court held that Samad had not shown expert testimony was required and granted Anglin’s motions for an extension of time and for issuance of a subpoena concerning jail video footage.

Holdings

  1. Summary judgment was denied because Samad did not establish that expert testimony was required as a matter of law to resolve Plaintiff's Fourteenth Amendment inadequate-medical-care claim.
  2. Plaintiff's claim was not treated as an Illinois medical malpractice claim for purposes of the motion because the Court's prior screening order limited it to a Fourteenth Amendment due process claim.

Questions Presented

  1. Whether Defendant Samad was entitled to summary judgment because Plaintiff had not disclosed expert testimony required to establish an Illinois medical malpractice claim.
  2. Whether the expert-testimony requirement applicable to certain medical malpractice claims governed Plaintiff's Fourteenth Amendment due process claim concerning inadequate medical care as a pretrial detainee.
  3. Whether Plaintiff should receive additional time to respond to discovery requests.
  4. Whether Plaintiff was entitled to issuance of a subpoena duces tecum for jail video footage relevant to an excessive-force claim.

Disposition

other

Cases Cited (19)

  • Zaya v. Sood, 836 F.3d 800, 804 (7th Cir. 2016)(followed)
  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 252 (1986)(followed)
  • Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986)(followed)
  • Spierer v. Rossman, 798 F.3d 502, 507 (7th Cir. 2015)(followed)
  • Melton v. Tippecanoe County, 838 F.3d 814, 818 (7th Cir. 2016)(followed)
  • Ogden v. Atterholt, 606 F.3d 355, 358 (7th Cir. 2010)(followed)
  • Vargas v. United States, 430 F. Supp. 3d 500, 510 (N.D. Ill. 2019)(distinguished)
  • Massey v. United States, 312 F.3d 272, 280 (7th Cir. 2002)(distinguished)
  • Donais v. United States, 232 F.3d 595, 598 (7th Cir. 2000)(distinguished)
  • Burton v. Downey, 805 F.3d 776, 784 (7th Cir. 2015)(followed)

Showing top 10 of 19.

Cited In (0)

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