Michael Weis v. S. Angel, et al.

Summary

The United States District Court for the Central District of Illinois conducted a merit review under 28 U.S.C. § 1915A of Michael Weis’s § 1983 complaint alleging deliberate indifference to serious medical needs. The court allowed Eighth Amendment claims to proceed against M. West, Megan Battles, Lindsay Boehm, and Berkman Gordon, while dismissing claims against S. Angel, Arvinder Arora, and K. McMann without prejudice. The court denied Weis’s motion for a preliminary injunction seeking an MRI and a bottom-bunk permit.

Holdings

1. The complaint sufficiently stated a deliberate-indifference claim against Boehm based on her alleged handling of Weis's back pain, refusal to refer him for an MRI, and refusal to issue a bottom-bunk permit.
2. The complaint sufficiently stated a deliberate-indifference claim against West based on her alleged direction that Weis return a soft cast despite knowledge of the outside orthopedist's recommendation concerning the cast.
3. The complaint sufficiently stated a deliberate-indifference claim against Battles based on her alleged failure to schedule follow-up appointments with the outside provider after being instructed to do so.
4. The complaint sufficiently stated a deliberate-indifference claim against Gordon based on his alleged failure to provide adequate care for Weis's continuing back pain during the April 30, 2026 visit.
5. The complaint failed to state deliberate-indifference claims against Angel, Arora, and McMann, and those defendants were dismissed without prejudice under Rule 12(b)(6) and § 1915A.
6. Weis was not entitled to a preliminary injunction because he failed to show a reasonable likelihood of success on the merits.

Questions Presented

1. Whether Weis stated an Eighth Amendment deliberate-indifference claim against Boehm, West, Battles, and Gordon.
2. Whether Weis stated an Eighth Amendment deliberate-indifference claim against Angel, Arora, and McMann.
3. Whether Weis was entitled to a preliminary injunction requiring prison medical staff to arrange an MRI and issue a bottom-bunk permit.

Disposition

other