Judge Candace Jackson-Akiwumi, who was nominated by President Biden to the Seventh Circuit court of appeals, cast the deciding vote in a 2-1 decision that partly reversed a lower court ruling and gave the son of a deceased prisoner the opportunity to prove his father’s claim that prison officials were liable for damages for deliberate indifference to his medical needs. Judge David Hamilton, who was nominated by President Obama, wrote the ruling, to which Judge Michael Brennan, who was nominated by Donald Trump, dissented. The September 2024 decision was in McDaniel v Syed.
What happened in this case? ,
Carl McDaniel had been confined in prison in Wisconsin for over fourteen years. During much of that time, he suffered from a number of serious medical conditions, some of which created significant mobility problems. These included, for example, chronic obstructive pulmonary disease, kidney disease, type 2 diabetes with neuropathy, fibromyalgia, chronic pain, and degenerative joint disease in his spine with spinal stenosis. He received spinal surgery, after which he could “move using a four-wheel walker.”
At the time of the surgery, McDaniel was in a non-stairs cell giving him access to meals and other prison facilities. Some months after the surgery, he was transferred to the Columbus Correctional Institution, where he had to climb stairs to obtain meals and prescribed drugs. Some prison officials maintained that climbing stairs was a part of his rehabilitation, but he repeatedly complained about the pain caused by frequent stair climbing. In order to access meals and the infirmary, he maintained, he had to walk up and down stairs “at least sixteen times each day.” Because this was so painful, he stated that he “missed some 600 meals” and many drug dosages in the year he was at Columbia.
Acting primarily on his own, McDaniel filed a lawsuit against prison officials under the ADA and the Rehabilitation Act, claiming that they were deliberately indifferent to his serious medical needs. In addition to the stairs problem, he also complained about other aspects of his confinement and about one particular doctor. The lower court granted summary judgment against him on all his claims. He was released from prison so that his claims for injunctive relief became moot, but continued to pursue his claims for damages. He appealed to the Seventh Circuit. After oral argument in the case, McDaniel died, and the case was pursued by his son.
How did Judge Jackson-Akiwumi and the Seventh Circuit Rule and Why is it Important?
All three judges on the panel affirmed the ruling against McDaniel on many of his claims. Judge Hamilton however, wrote a 2-1 decision made possible by Judge Jackson-Akiwumi that reversed the lower court on McDaniel’s claims concerning his need for a no-stairs unit and sent the case back to the lower court, where McDaniel’s son can pursue his father’s damages claims on that issue.
After carefully reviewing the record and relevant case law, Judge Hamilton wrote that there was “ample evidence” to support a jury finding in favor of McDaniel on the no-stairs issue. There was clearly a “material dispute” of facts, Hamilton continued, as to whether prison officials’ no-stairs decision represented good faith medical judgment or improper refusal to accommodate McDaniel’s serious medical needs, which a jury should decide.
The decision made possible by the deciding vote of Judge Jackson-Akiwumi was obviously important to the son of Carl McDaniel, who can now pursue his father’s claim for damages and justice for the pain and mistreatment he contended that he suffered. It also provides an example of court treatment of a claim for relief by a prisoner where officials assert their conduct was justified by medical judgment that may be useful in other cases, particularly in the Seventh Circuit, which includes Wisconsin, Illinois, and Indiana. In addition, the decision serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.