Jeffrey Lamont Lee v. Candice Andrychowicz, et al.

Summary

The United States District Court for the Eastern District of Wisconsin granted defendants’ motion for summary judgment in Jeffrey Lamont Lee’s 42 U.S.C. § 1983 action. The court held that Lee failed to establish an objectively extreme deprivation of bathroom access or an injury caused by the discontinuation of his special handling note, and therefore rejected his Eighth Amendment conditions-of-confinement and deliberate-indifference claims. The case was dismissed.

Holdings

1. Defendants were entitled to summary judgment because Lee did not establish an objectively serious deprivation of toilet access or other extreme deprivation. The evidence showed that he used the bathroom during the incidents described and was punished afterward, rather than being denied access to the toilet.
2. Burton was entitled to summary judgment because Lee failed to establish that Burton's conduct caused him an actual injury.
3. Summary judgment was proper because, on the record as a whole, no reasonable factfinder could find for Lee on either claim.

Questions Presented

1. Whether defendants subjected Lee to an objectively serious deprivation of the minimal civilized measure of life's necessities by restricting or discontinuing his special handling note and by enforcing bathroom restrictions during prison counts.
2. Whether Burton was deliberately indifferent to Lee's serious medical needs under the Eighth Amendment.
3. Whether defendants were entitled to summary judgment because Lee failed to establish a constitutional deprivation, causation, or an actual injury.

Disposition

dismissed