McCann v. Ogle County, No. 17-3139 (7th Cir. 2018)Annotate this Case
McCann was severely burned while attempting to commit arson at his mother’s house and spent three weeks in the hospital before being released to police custody. McCann died from a doctor’s over-prescription of methadone while detained and awaiting trial at the Ogle County Correctional Center. His estate brought suit under 42 U.S.C. 1983, alleging deliberate indifference to McCann’s severe burn wounds and related medical needs. The treating physician and his private employer settled the claims. The district court entered summary judgment for the remaining defendants, concluding that the evidence did not show that any individual defendant acted with deliberate indifference. The Seventh Circuit subsequently replaced deliberate indifference with a standard requiring a showing of objective reasonableness for a claim challenging the medical care provided to a pretrial detainee like McCann. Measuring the record evidence under this new standard, the Seventh Circuit affirmed the award of summary judgment to the individual defendants and a determination that the record evidence did not support a claim for municipal liability against Ogle County under Monell.