Medical Care Beneath Constitutional Standards

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7^th Circuit Court of Appeals

Case Name: Richard Rodgers v. William Rankin

Case No.: 23-1220

Officials: Easterbrook, Hamilton, and Brennan, Circuit Judges.

Focus: Medical Care Beneath Constitutional Standards

Richard Rodgers, a prisoner with a medical history of scoliosis and back pain, had steel rods implanted in his back prior to his imprisonment. Unfortunately, while in prison, these rods broke, a condition that went undetected for over a year due to two radiologists misinterpreting his x-rays. Dr. William Rankin, the primary care physician at the prison, eventually discovered the broken rods and organized corrective surgery. Rodgers filed a lawsuit against both the radiologists and Dr. Rankin, alleging a violation of his Eighth Amendment rights.

The district court dismissed Rodgers’ claims against the radiologists, stating that he failed to present a valid constitutional claim against them. While Rodgers was allowed to continue his case against Dr. Rankin, the court eventually ruled in favor of the physician, granting summary judgment. The court determined that Rodgers hadn’t provided sufficient evidence for a reasonable jury to conclude that Dr. Rankin had shown deliberate indifference towards Rodgers’ serious medical condition.

The Seventh Circuit agreed that Rodgers’ accusations against the radiologists amounted to negligence rather than a viable Eighth Amendment claim. Concerning Dr. Rankin, the court found no substantial evidence to support the claim of deliberate indifference. It highlighted Dr. Rankin’s role in uncovering the radiologists’ mistakes and facilitating Rodgers’ corrective surgery.

Affirmed.

Decided 04/23/24

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