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Justia Daily Opinion Summaries

US Court of Appeals for the Seventh Circuit
March 16, 2021

Table of Contents

Patterson v. Baker

Civil Rights, Constitutional Law, Criminal Law

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US Court of Appeals for the Seventh Circuit Opinions

Patterson v. Baker

Docket: 19-2917

Opinion Date: March 15, 2021

Judge: Scudder

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

Illinois inmate Patterson testified that his repeated requests to be moved from an unheated cell were ignored and, to get attention, he violated the rules. On February 7, officers repeatedly ordered Patterson to remove a paper covering from his cell window. Patterson testified that the officers returned later and beat him by punching him where bruising would go unnoticed, stripped him naked, paraded him around the cell block, and ignored his request for medical treatment. He claims he endured another beating two days later at the hands of different officers. The officers testified that after Patterson refused to remove the window covering, they found Patterson naked in his cell and moved him to another cell. They denied any other physical contact. On February 10, Patterson saw Licensed Practical Nurse Aldridge, who testified that Patterson reported scrapes, neck and ankle pain, and swelling of his wrists. She saw “no visible signs” of injury other than small scrapes on his wrists. She diagnosed Patterson with a “minor” “soft tissue injury.” In a suit under 42 U.S.C. 1983, the Seventh Circuit affirmed a judgment in favor of the officers, rejecting Patterson’s argument that the district court never should have allowed Nurse Aldridge, who testified as a fact witness, to offer an expert opinion on recross about whether, based on Patterson’s account of the beatings he experienced, she would have anticipated seeing signs of injury during her examination of him on February 10.

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