Seventh Circuit Rules Against Prisoner’s Deliberate Indifference Claim Over Wexford Health’s Poor Psychiatric Care
Cordell Sanders spent eight years in segregation housing at the Pontiac Center in Indiana after committing multiple disciplinary offenses. While being held apart from others, he suffered from severe mental health issues, harmed himself, attempted multiple times to take his own life, and was found to suffer antisocial personality disorder, intermittent explosive disorder, schizoaffective disorder, and depressive disorder. Psychologists and psychiatrists employed by Wexford Health created treatment plans as a result that included antidepressants, psychotropic, and mood stabilizing drugs. He has since then brought a lawsuit against the Illinois Department of Corrections health services provider Wexford Health Sources, Inc. for deliberate indifference to his mental health needs by failing to advocate for his removal from administrative segregation resulting in the exacerbation of his mental health issues.
The district court granted a Motion for Summary Judgement filed by the defendants. Sanders appealed and it was affirmed on August 28, 2025.
Circuit Judge Lee noted the tragedy of this case, pointing to Sanders’ severe mental health problems and that the segregation “did little to address them.” Nevertheless, he found that Sanders had been unable to overcome the very high bar of deliberate indifference. Lee cited yet another Wexford case, Stewart v. Wexford Health Source, Inc., 14 F.4th 757,762 (7th Cir. 2021), “[a] medical professional is entitled to deference in treatment decisions unless no minimally competent professional would have so responded under those circumstances.” The Court deciding the Stewart case quoted Huber v. Anderson, 909 F.3d 201,208 (7th Cir. 2018), stating that it “requires more than negligence or even gross negligence, a plaintiff must show that the defendant was essentially criminally reckless.” Sanders brought an expert witness to testify on his behalf, but the expert did not offer any opinions, beyond the psychiatric impact of the segregation, other than that the defendants failed to “spend sufficient time with Sanders to ‘really get[] to know him.’” That difference of medical opinion was insufficient to support a finding of deliberate indifference.
Circuit Court Judge Rovner issued a concurring opinion in which he emphasized the evolving view of administrative segregation. “Despite (or perhaps because of) spending eight years in continuous solitary confinement, [Sanders] was unable to conform his behavior to prison expectations or to act in a manner that benefited his own interest,” Rovner said. “[T]he abundant research describing the destructive and devastating mental health effects of even the most minimal time in solitary confinement” shows the effects to be universal. Rovner added, “reducing solitary confinement decreases prison violence dramatically.”
The current standard for deliberate indifference was too high a bar, but Rovner continued, “[I]t is my hope that our ever-evolving understanding of the psychological effects of solitary confinement on the one hand, and lack of psychological benefit, on the other, will inform our understanding of deliberate indifference, liberty interests, and Eighth Amendment standards in cases where defendants were, in fact, responsible for imposing the condition.” See: Sanders v. Moss, No. 23-1335, 2025 U.S. App. LEXIS 22196 (7th Cir. Aug. 28, 2025).
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Related legal cases
Stewart v. Wexford Health Sources, Inc.
| Year | 2021 |
|---|---|
| Cite | 14 F.4th 757 (7th Cir. 2021) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
Huber v. Anderson
| Year | 2018 |
|---|---|
| Cite | 909 F.3d 201,208 (7th Cir. 2018) |
| Level | Court of Appeals |