James Hampton v. Pam Ward

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted January 13, 2026*
Decided January 14, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
MICHAEL Y. SCUDDER, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 24-2945
JAMES HAMPTON,
Plaintiff-Appellant,
v.
PAM WARD,
Defendant-Appellee.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 20-cv-1300-DWD
David W. Dugan,
Judge.
O R D E R
James Hampton, an Illinois prisoner, sued Pam Ward, a prison nurse, for
deliberate indifference to his medical needs when she allowed him to be handcuffed
behind his back despite a preexisting hernia. The district court entered summary
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-2945 Page 2
judgment for Ward because Hampton did not show that Ward knew of his hernia or
could have altered his handcuffing.† We affirm.
We recount the facts in the light most favorable to Hampton, the nonmovant.
See Quinn v. Wexford Health Sources, Inc., 8 F.4th 557, 565 (7th Cir. 2021). While Hampton
was imprisoned at Lawrence Correctional Center, he developed a hernia, and prison
doctors referred him for a surgical consultation at a nearby hospital. On the day of his
surgical consultation, however, he was handcuffed behind his back for three hours
while prison officers searched his cell block. About two-and-a-half hours into being
handcuffed, Hampton felt a pop in his abdomen and became dizzy. Hampton asked for
help and told a nearby correctional officer that he had a medical permit for alternative
handcuffing (either in front or double handcuffs behind his back) that would reduce
pain from his hernia. The officer asked Ward, who was attending to another inmate, if
Hampton had such a permit. She called the health services unit, learned that Hampton
did not have such a permit, and shared that answer with the officer. Hampton remained
handcuffed for another half hour. Hampton alleges that because he was handcuffed
behind his back for multiple hours, his single hernia became five hernias. At the time,
Hampton did not have a permit for alternative cuffing, but a doctor gave him one after
the surgical repair of his hernias.
Hampton filed this lawsuit under 42 U.S.C. § 1983, alleging that Ward acted with
deliberate indifference to his medical needs in violation of the Eighth Amendment by
allowing him to remain handcuffed for about 30 minutes after he requested alternative
cuffing.
In a deposition, Hampton explained that he was not sure whether Ward knew of
his hernia when she called the health services unit but that he told her of the hernia
sometime thereafter, while he was still handcuffed. Hampton also did not know
whether Ward had the authority, as a nurse, to instruct officers to change his
handcuffing.
The district court granted Ward’s motion for summary judgment, reasoning that
Hampton failed to introduce evidence that Ward knew of an objectively serious risk of
harm to Hampton or had authority to grant him a medical permit for alternative
handcuffing.
† Hampton’s claims against other defendants were all settled or dismissed. He
appeals only the district court’s judgment on his claim against Ward.

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No. 24-2945 Page 3
On appeal, Hampton maintains that Ward acted with deliberate indifference
when she failed to do more than determine that he did not have a permit for alternative
cuffing. To establish liability for deliberate indifference, the plaintiff must show that the
defendant knew of and disregarded a substantial risk of harm to the plaintiff. Farmer v.
Brennan, 511 U.S. 825, 837 (1994); Petties v. Carter, 836 F.3d 722, 728 (7th Cir. 2016)
(en banc). Defendants “can avoid liability by proving they were unaware even of an
obvious risk to inmate health or safety.” Petties, 836 F.3d at 728. Additionally, because
nurses generally must defer to the judgment of doctors managing a prisoner’s
treatment, they are not liable for deliberate indifference unless that deference is “blind
or unthinking.” Reck v. Wexford Health Sources, Inc., 27 F.4th 473, 485 (7th Cir. 2022)
(citation omitted).
Hampton has not offered evidence from which a reasonable jury could conclude
that Ward acted with deliberate indifference. Hampton admitted that Ward had no
prior knowledge of his condition or medical needs and that when he claimed to have a
medical permit for alternative cuffing, Ward promptly requested confirmation but
learned that Hampton’s doctor had not ordered such a permit. Hampton asserts that,
nonetheless, Ward should have instructed officers to alter his restraints or requested
further assistance from the health services unit. But Hampton has not provided any
evidence that Ward knew that standard handcuffing presented a substantial risk of
harm to someone with a hernia, as he must to successfully defend against Ward’s
motion for summary judgment. See Petties, 836 F.3d at 728.
To the extent Hampton argues that Ward should have done something to treat
his pain once he told her he was in pain from his hernia, we cannot say that any
“inexplicable delay” in treatment exacerbated an injury or unnecessarily prolonged
pain, which Hampton must establish to show deliberate indifference under such a
theory. Petties, 836 F.3d at 730–31; see also Howell v. Wexford Health Sources, Inc., 987 F.3d
647, 653, 661 (7th Cir. 2021). Ward was treating another inmate when Hampton asked
nearby officers for help, explaining any delay. Hampton has not shown that the
30 minutes he remained handcuffed after Ward learned of his pain resulted in any
injury. And Hampton saw a surgical specialist to treat his hernias later that day.
Hampton’s evidence does not show the disregard of pain that establishes a claim of
deliberate indifference. See, e.g., Grieveson v. Anderson, 538 F.3d 763, 779 (7th Cir. 2008)
(defendants not entitled to summary judgment where guards needlessly delayed
treatment of plaintiff's broken nose for a day and a half); Edwards v. Snyder, 478 F.3d

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No. 24-2945 Page 4
827, 831 (7th Cir. 2007) (plausible claim where plaintiff was needlessly denied treatment
for dislocated finger for two days).
AFFIRMED

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