Andrew Lamon v. R-4 Control Officer (Alina Bleisch)

Summary

The United States District Court for the Southern District of Illinois denied a correctional officer’s motion for summary judgment in an inmate’s action arising from a delayed response to emergency calls during a cardiac event. The court held that factual disputes could support an Eighth Amendment deliberate-indifference claim based on the officer’s alleged failure to respond to repeated emergency call signals and that pain caused by the delay could constitute a cognizable injury. The court also allowed the inmate’s Illinois intentional-infliction-of-emotional-distress claim and declined to grant qualified immunity at the summary-judgment stage.

Holdings

1. Summary judgment was improper because the evidence, viewed in Lamon's favor, could support a finding that Bleisch was aware of a serious risk of harm from repeated emergency calls and deliberately disregarded that risk, even if she did not know the specific medical condition or its full severity.
2. The alleged thirty-minute delay could support an Eighth Amendment claim based on severe pain attributable to the delay, even if Lamon could not prove that the delay caused the heart attack or other medical harm.
3. Summary judgment was improper on Lamon's Illinois IIED claim because the evidence could permit a jury to find that Bleisch's conduct was extreme and outrageous, undertaken with reckless disregard for the risk of severe emotional distress, and causally related to the alleged distress.
4. Bleisch was not entitled to qualified immunity at the summary-judgment stage because the evidence could establish a constitutional violation and the right to be free from deliberate indifference to a serious risk to inmate health or safety was clearly established.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on Lamon's Eighth Amendment deliberate-indifference claim based on an alleged delay in responding to repeated emergency calls.
2. Whether the alleged delay could support an Eighth Amendment claim based on pain and other harm even if the evidence did not establish that it caused the cardiac event or additional medical injury.
3. Whether genuine disputes of material fact precluded summary judgment on Lamon's Illinois intentional-infliction-of-emotional-distress claim.
4. Whether Bleisch was entitled to qualified immunity on the deliberate-indifference claim.

Disposition

other