Hill v. Wexford, et al.

Summary

In this merit review order, the United States District Court for the Central District of Illinois screened Demeco Hill’s 42 U.S.C. § 1983 complaint concerning delayed and inadequate medical care after a prison injury. The court dismissed all claims without prejudice under Federal Rule of Civil Procedure 12(b)(6) and 28 U.S.C. § 1915A, finding insufficient allegations of personal involvement, an unconstitutional policy or practice, or deliberate indifference, and noting potential statute-of-limitations issues. The court granted Hill 30 days to file a complete amended complaint.

Holdings

1. A prisoner asserting deliberate indifference must allege both an objectively sufficiently serious medical condition and a subjectively culpable state of mind showing that the defendant knew of and disregarded an excessive risk to the prisoner's health.
2. Section 1983 does not impose respondeat superior liability; a defendant must have personally participated in the constitutional deprivation or been deliberately reckless or knowingly acquiescent regarding subordinate misconduct.
3. A private corporation performing a governmental function may face § 1983 liability only when an unconstitutional policy, practice, custom, or decision by a final policymaker caused the constitutional injury; it is not vicariously liable for employees' alleged misconduct.
4. Conclusory and threadbare allegations that a nurse failed to respond adequately to sick-call requests, without specifying the requests, timing, or manner of deliberate indifference, do not state a plausible deliberate-indifference claim.
5. Section 1983 claims in Illinois are generally subject to a two-year statute of limitations, and dismissal under Rule 12(b)(6) may be appropriate when the complaint itself establishes all elements of an affirmative limitations defense.

Questions Presented

1. Whether the complaint stated a plausible Eighth Amendment deliberate-indifference claim against the warden, healthcare administrator, private medical contractor, IDOC Administration, or sick-call nurse.
2. Whether the claims against the supervisory and institutional defendants could proceed without allegations of personal participation or an unconstitutional policy, practice, or custom.
3. Whether the allegations appeared barred by the applicable two-year statute of limitations.
4. Whether dismissal should be without prejudice with leave to amend.

Disposition

dismissed