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Seventh Circuit Reverses Dismissal of Federal Prisoner’s Bivens Suit Over Medical Care

Ryan K. Mathison, incarcerated at FCI Pekin, a federal prison near Peoria, Illinois, suffered from high blood pressure. One morning he awoke at 3 a.m. with a sharp pain in his chest; he summoned a guard, who called a lieutenant, who in turn contacted the duty nurse. Although the lieutenant said he thought Mathison was suffering a heart attack, without examining him the nurse concluded he was not.

Four hours after first experiencing chest pains, Mathison was taken to the prison infirmary, where he was examined and immediately sent to a local hospital. The hospital staff diagnosed his condition as a heart attack, installed a stent and kept him for observation for two days, after which he was returned to the prison.

Mathison then filed a Bivens action against the guard, the lieutenant, and the prison nurse and physician, alleging they had been deliberately indifferent to his life-threatening medical condition. The district court granted summary judgment to all the defendants, holding that a prisoner was not entitled to the same level of medical care as a non-prisoner.

Mathison appealed and the Seventh Circuit rejected the lower court’s reasoning, reinstating his lawsuit against the nurse and supervising lieutenant but affirming the dismissal of his claims against the guard and the prison doctor.

The appellate court noted that the guard had no medical training and promptly notified his superior, a lieutenant who had the authority to summon an ambulance and transport Mathison to a hospital. They also found no fault with the prison physician, who, upon first examining Mathison when he arrived at the infirmary, had him transferred to a hospital that could treat him. The Court of Appeals faulted the prison nurse for failing to personally examine Mathison even after being advised by the lieutenant that he was suffering symptoms consistent with a heart attack.

The Seventh Circuit also stated in its February 8, 2016 ruling that case law required the prison to provide more than just basic medical care: “We think that civilization requires more in a life and death situation, and are left to wonder what the [district court] judge thinks the minimum level of care is to which a prisoner who is suffering a heart attack is entitled.” See: Mathison v. Moats, 812 F.3d 594 (7th Cir. 2016).

Following remand, Mathison submitted a bill of costs to the district court for the $505 appellate filing fee, which was granted. The case remains pending. 

Related legal case

Mathison v. Moats


 

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