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$4,500 Jury Award in Delayed Medical Treatment of Illinois Prisoner Upheld

The Seventh Circuit Court of Appeals has held that "verifying medical evidence" to support a prisoner's delayed medical treatment claim can come from the prisoner's medical records and the prisoner.

That ruling came in the appeal of prison officials after an Illinois federal jury found them liable, awarding the prisoner $4,500 in compensatory damages, for delaying medical care for six hours. Illinois prisoner David Williams, an obese prisoner who suffers from high blood pressure, began experiencing chest pain around 6:30 a.m. in the segregation unit of the Menard Correctional Center.

Around 7 a.m., Williams advised guard James Massey that he needed help for his chest pain. Massey advised Williams that he was being released from segregation that day for a transfer to protective custody and to wait until the transfer was completed to get help. Around 10:30, Massey escorted Williams down four flights of stars, removed his handcuffs, and gave him a pushcart with his property. Before he left, Williams requested to see the medical technician. Massey told him to speak to someone at the property building, which was 100 yards away.

Once at the property building, Williams requested guard Brent Hoffman to summon a doctor or paramedic because he was having chest pains, his arm was numb, he was sick, and he was sweating profusely. Hoffman ignored Williams' request, ordering him to help other prisoners with their property and to carry his own 200-pound box.

Williams was then instructed to push a property cart to the clothing building that was 200-250 yards away, and then to the cellhouse that was another 100 yards. Williams was then forced to carry his box into his cell. He requested guard James Liefer to get him medical help because he was suffering chest pain, showing him an identification card that stated Williams suffered from hypertension. Around 1:00 p.m., Williams began to carry his property up a flight of stairs after Liefer ignored him. As he climbed the stairs, Williams blacked out and fell backwards down the stairs.

Once he arrived at the prison emergency room, Williams was given nitroglycerin. Within an hour, he recovered, but spent six days in the infirmary. An EKG revealed Williams had a first-degree AV block, which could signify other coronary artery disease or hypertension. At trial, Williams testified that as a result of the October 27, 2000 injuries, he could not walk long distances or work a job.

On appeal, the defendants argued Williams showed no present evidence of harm. In cases where prison officials delayed rather than denied medical assistance to a prisoner, courts require the plaintiff to offer "verifying medical evidence" that the delay (rather than the prisoner's underlying condition) caused some degree of harm. That is, the plaintiff must offer medical evidence that tends to confirm or corroborate a claim that the delay was detrimental.

The Seventh Circuit found that while a jury could not determine whether the delay in treatment or the underlying condition affected Williams' ability to work, it could have concluded from the medical records that the delay unnecessarily prolonged and exacerbated Williams' pain and unnecessarily prolonged his high blood pressure. Thus, the delay caused six hours of extra pain.

Finally, the Court rejected the defendants argument that the law concerning verifying medical evidence was not settled entitled them to qualified immunity because that does not play into a guards decision of whether to seek medical treatment for a prisoner. As such, the jury's July 5, 2006, verdict was affirmed. See: Williams v. Liefer, 491 F.3d 710 (7th Cir. 2007).

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Related legal case

Williams v. Liefer