Budd v. Motley, No. 11-3425 (7th Cir. 2013)
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Following his arrest in 2009, Budd spent 45 days in the Edgar County Jail. In newspaper articles, the sheriff described the jail as not “livable” and violating “acceptable standards.” During his detention, Budd was confined with eight inmates in a space intended for three; he had to sleep on the floor alongside broken windows and cracked toilets. After another arrest, Budd returned to the jail. Vents were blocked, the heating and air conditioning systems did not work, and inmates were denied any recreation. During a third stay at the facility, something scratched or bit Budd’s leg. After infection set in, the jail nurse gave Budd ice. Budd wrote to the sheriff asking to see a doctor. Over the course of several hospital visits, he received tests, medication, and an MRI. He developed a “hole in [his] leg,” which doctors attributed to unsanitary conditions at the jail. He became “hysterical” at the prospect of returning to the jail. A judge ordered that he be taken to another facility. After a video conference to screen Budd’s 42 U.S.C. 1983 complaint, the district court dismissed, but furnished no written statement of reasons and did not prepare a transcript. The Seventh Circuit vacated and remanded.
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