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2160554.5 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

 

Hundley Lynn Ford, Jr., 

Plaintiff, 

v. 

Wexford Health Sources, Inc., 

S. A. Godinez, Marcus Hardy, 

Darryl Edwards, Nancy Pounovich, 

Anna McBee, Landria Dennis, 

Parthasarathi Ghosh, Imhotep Carter, 

Latonya Williams, and Joseph Sheehey, 

Defendants. 

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Case No. 1:12-CV-04558 

Hon. Amy St. Eve 

PLAINTIFF’S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS’

MOTION TO DISMISS

Plaintiff, Hundley Lynn Ford Jr. (“Mr. Ford”), submits this Memorandum of Law in 

Opposition to Defendants Wexford Health Source, Inc., Parthasarathi Ghosh, Imhotep Carter, 

and Latonya Williams’ (collectively, “Defendants”) Motion to Dismiss Plaintiff’s Amended 

Complaint. Co-Defendants S.A. Godinez, Marcus Hardy, Darryl Edwards, Nancy Pounovich, 

Anna McBee, Landria Dennis and Joseph Sheehey have not moved to dismiss the claims brought 

against them, and instead have answered. (Dkt. 40.) 

INTRODUCTION 

On June 12, 2012, after four years of prolonged, severe, and untreated back pain, 

Mr. Ford filed a pro se Complaint in this Court. (Dkt. 1.) On June 15, 2012, this Court issued an 

Order pursuant to 28 U.S.C. § 1915A, finding that Mr. Ford “has articulated a colorable federal 

cause of action with respect to deliberate indifference of serious medical condition.” (Dkt. 5 at 

2.) This Court then appointed the undersigned counsel to represent Mr. Ford. On August 30, 

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2012, Mr. Ford filed an Amended Complaint (“Complaint”) further detailing the basis for his 

claims against Defendants. (Dkt. 12.) 

In response to Mr. Ford’s detailed Complaint, Defendants Wexford, Ghosh, Carter, and 

Williams filed what appears to be an off-the-shelf, pro forma motion to dismiss. In filing their 

formulaic motion, Defendants perpetuate their longstanding failure to appreciate the nature of 

Mr. Ford’s serious medical condition and the importance of promptly addressing that condition. 

Mr. Ford’s detailed Complaint easily meets the minimum notice pleading requirements of Fed. 

R. Civ. P. 8(a)(2). 

STANDARD OF REVIEW 

To survive a motion to dismiss, a complaint need only contain sufficient facts to state a 

claim for relief that is plausible on its face. Young v. Wexford Health Sources, Inc., No. 10 C 

8220, 2012 U.S. Dist. LEXIS 17416, at *5 (N.D. Ill. Feb. 12, 2012). When ruling on a 

defendant’s motion to dismiss, the court accepts as true all of the factual allegations contained in 

the complaint and draws all reasonable inferences in the plaintiff’s favor. McDonald v. Wexford 

Health Sources, Inc., No. 09 C 4196, 2010 U.S. Dist. LEXIS 78276, at *4 (N.D. Ill. July 30, 

2010). Further, particularly where constitutional rights are concerned, the Seventh Circuit has 

been reluctant to dismiss inmate complaints at this early stage in the litigation. See LaBatt v. 

Twomey, 513 F.2d 641, 650 (7th Cir. 1975) (“We have previously noted the serious question as 

to whether the summary judgment procedure should ever be employed against an incarcerated 

party. . . . [A]n overriding interest must be fairness to the parties, especially where important 

constitutional rights are asserted.”) (internal citations omitted). 

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ARGUMENT 

Defendants’ motion to dismiss should be denied for the following three reasons: 

First, Defendants misstate the facts and misconstrue the governing legal standard. Mr. 

Ford has adequately pleaded facts which demonstrate that not only were defendants aware of 

Mr. Ford’s serious medical need, but Defendants repeatedly failed to follow through on 

treatment Defendants themselves determined was appropriate. Even Defendants’ own case law 

demonstrates that Defendants’ inaction amounts to a deliberate indifference to medical need. 

Second, Defendants’ conclusory assertion of the qualified immunity defense ignores that 

Mr. Ford has adequately alleged a violation of his rights under the Eighth Amendment of the 

United States Constitution, and that the standards governing Defendants’ conduct were clearly 

established at the time of Defendants’ inaction. 

Third, Mr. Ford’s Complaint contains detailed allegations regarding policies and 

practices of delaying medical appointments, delaying the dispensing and renewing of 

prescriptions and permits, and delaying treatment by third party medical care providers as cost 

saving measures. Additionally, Mr. Ford not only alleged Defendant Carter enacted an express 

policy of voiding Defendant Dr. Ghosh’s orders as part of the effort to cut costs, but Mr. Ford 

also attached documents to his Complaint evidencing the existence of that policy. Mr. Ford has 

easily met, and exceeded, the minimum pleading requirements of Fed. R. Civ. P. 8(a)(2). 

I. Mr. Ford has Adequately Plead a Claim for Deliberate Indifference to Medical 

Need. 

To state a claim for relief under Fed. R. Civ. P. 8(a)(2), a plaintiff need only make “a 

short and plain statement of the claim showing that the pleader is entitled to relief, in order to 

‘give the defendant fair notice of what the . . . claims is the grounds upon which it rests.” Jones 

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v. Boruta, No. 10 C 2961, 2011 U.S. Dist. LEXIS 62387, at *2 (N.D. Ill. May 31, 2011) (quoting 

Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)); Fed. R. Civ. P. 8(a)(2). 

Prison officials violate the Eight Amendment’s prohibition against cruel and unusual 

punishment when they display deliberate indifference to the serious medical needs of prisoners. 

See Sherrod v. Lingle, 223 F.3d 605, 610 (7th Cir. 2000). Generally, the existence of deliberate 

indifference is a fact intensive inquiry, inappropriate for a motion to dismiss. See Watkins v. 

Ghosh, No. 11 C 1880, 2011 U.S. Dist. LEXIS 136000, at *15 (N.D. Ill. Nov. 28, 2011). 

Defendants do not dispute that Mr. Ford has adequately alleged that he suffers from an 

objectively serious medical condition. Instead, Defendants argue that they were not aware of 

Mr. Ford’s serious medical need, or alternatively, even if they were aware of Mr. Ford’s 

condition, they were not deliberately indifferent to Mr. Ford’s need. Despite Defendants’ 

assertion about their claimed lack of knowledge, in the context of reviewing a motion to dismiss, 

the Court must accept as true all well plead allegations in the Complaint. And as even a brief 

review of the Complaint will demonstrate, Mr. Ford has adequately pleaded that each of the 

Defendants were deliberately indifferent as to Mr. Ford’s serious medical need. (Compl. ¶¶ 23, 

25, 30, 32, 35, 37, 40, 42, 45, 67.) 

A. Defendant Ghosh Was Personally Involved in the Delay and Denial of 

Mr. Ford’s Medical Treatment. 

For several reasons, Mr. Ford’s Complaint satisfies any pleading standard governing his 

claims against Defendant Ghosh. First, Defendants misstate the allegations contained in Mr. 

Ford’s Complaint. It is a settled principle that prison officials must be personally involved in the 

constitutional deprivation alleged in order to be held liable. Watkins, 2011 U.S. Dist. LEXIS 

136000, at *15. And, based on this principle, Defendants argue that Defendant Ghosh “is not a 

mind-reader and he cannot be held liable for delays in treatment he is not aware of.” (Mot. at 8.) 

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But that argument entirely misses the point of Mr. Ford’s Complaint. Defendants concede, in the 

very same paragraph of their brief where they contend that Defendant Ghosh is not a mind 

reader, that Mr. Ford “alleges that he wrote to Defendant Ghosh numerous times to notify him 

that he was still waiting for treatment.” (Mot. at 8.) By alleging that Mr. Ford wrote to 

Defendant Ghosh on multiple occasions and put Defendant Ghosh on notice, Mr. Ford has 

adequately alleged Defendant Ghosh’s personal knowledge of his condition and that he was not 

receiving the treatment Dr. Ghosh had ordered. (Compl. ¶¶ 30, 32, 35, 37.) Watkins, 2011 U.S. 

Dist. LEXIS 136000, at *18 (where a grievance is sent directly to defendant, “we can infer that 

[defendant] had actual knowledge of [plaintiff’s] injuries and the ongoing denial of treatment for 

those injuries but failed to take action.”). 

Second, Defendants misstate the law. Defendants argue that Mr. Ford “does not attach 

any of the alleged letters [sent to Defendant Ghosh]” to his Complaint. (Mot. at 8.) Defendants 

misunderstand the standard governing a 12(b)(6) motion to dismiss. To state a claim for relief, 

Mr. Ford need only allege facts sufficient to state a claim and need not prove his claim via 

attachments to his Complaint. See Young, 2012 U.S. Dist. LEXIS 17416, at *4-5. 

Third, Defendants’ Motion exhibits the same inability and unwillingness to understand 

Mr. Ford’s medical history that lead to the extraordinary delay and denial of treatment which 

resulted in this litigation. Although Mr. Ford was referred to the UIC Pain Clinic on January 19, 

2011, contrary to Defendants’ misrepresentation of the allegations in the Complaint, Mr. Ford 

did not visit the UIC Pain Clinic in May of 2011. (Mot. at 8; Compl. ¶¶ 37, 41, 44, 47, 57.) 

After injuring his back in April, 2008, Mr. Ford did not receive treatment at the UIC Pain Clinic 

in 2008, 2009, 2010, or 2011. (See Compl. ¶¶ 18, 23, 25, 30, 33, 37, 41, 44, 47, 57-64.) 

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Fourth, even Defendants’ own case law makes clear that Mr. Ford has adequately alleged 

that Defendant Ghosh was deliberately indifferent as to Mr. Ford’s medical need. (Mot. at 12 

(citing Flournoy v. Ghosh, No. 07 C 5297, 2012 U.S. Dist. LEXIS 103388 (N.D. Ill. July 24, 

2012)).) In Flournoy, the plaintiff inmate suffered a delay of over a year in his referral to the 

UIC ophthalmology department. Id. at *19. In the interim, plaintiff repeatedly notified doctors, 

including Dr. Ghosh, that his prescriptions were not being renewed on a timely basis. Id. at *24. 

As a result of the persistent delays, plaintiff’s condition deteriorated to the point that he required 

surgery. Id. at *7. In denying Dr. Ghosh’s motion for summary judgment, the court rejected Dr. 

Ghosh’s argument that “once he wrote the prescriptions, the matter was out of his hands.” Id. at 

*25. 

Mr. Ford suffered a prolonged delay in his referral to the UIC Pain Clinic and repeated 

lapses in the filling and renewal of his prescriptions. (Compl. ¶¶ 31, 37, 42, 47.) Mr. Ford wrote 

to Defendant Ghosh and notified him he was still waiting for the treatment Dr. Ghosh had 

oredered. (Compl. ¶ 37.) In the absence of treatment, Mr. Ford’s condition continued to worsen, 

as he suffered prolonged pain and suffering, and multiple episodes in which his condition left 

him immobile in his cell, unable to leave his cell for lunch or dinner. (Compl. ¶ 37, 40-41.) 

Defendant Ghosh cannot absolve himself of responsibility by writing an order alone. See 

Flournoy, 2012 U.S. Dist. LEXIS 103388, at *25. As medical director, Defendant Ghosh had 

responsibility for the coordination of Stateville’s health-care program and “Ghosh cannot escape 

responsibility by claiming that all he was required to do was hand a prescription over . . . .” Id. 

Finally, Defendants rely on inapposite case law to further argue that Defendant Ghosh 

cannot be expected to have day-to-day knowledge of the lack of treatment of prisoners. (Mot. at 

7-8). As a preliminary matter, Mr. Ford alleges that Defendant Ghosh failed to act on his 

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personal knowledge of Mr. Ford’s lack of treatment, not that Defendant Ghosh failed to act on 

general knowledge as to anonymous prisoners. (Compl. ¶¶ 35, 37.) Defendants inexplicably cite 

to Duncan v. Duckworth, 644 F.2d 653, 655 (7th Cir. 1981) to support the argument that “it is 

not proper to presume” that Defendant Ghosh would have knowledge of Mr. Ford’s denial of 

treatment. (Mot. at 8.) As Defendants note, Duncan observes that “it is doubtful that a prison 

warden would be directly involved in the day-to-day operation of the prison hospital . . .” (Mot. 

at 8 (citing Duncan, 644 F.2d at 655).) But the Seventh Circuit’s teaching in Duncan is 

inapplicable here. Defendant Ghosh was not the warden, he was the medical director. (Compl. ¶ 

13.) The issue here is the responsibilities of a medical director as to medical care, not the prison 

warden’s knowledge of the provision of medical care. As the court spelled out clearly in 

Flournoy, which Defendants themselves cite to, Wexford’s contract for services with the IDOC 

mandates that “the ‘On-site Medical Director at the Center’ . . [is] the ‘medical authority’ of the 

site and [is] charged with operating ‘the health care program . . . . The On-site Medical director 

shall plan, implement, direct and control all aspects of the health care program.’” Flournoy, 

2012 U.S. Dist. LEXIS 103388, at *14. Not only has Mr. Ford alleged facts to show Defendant 

Ghosh had personal knowledge of the delay and denial of Mr. Ford’s treatment (Compl. ¶ 45, 57) 

but Duncan does not alleviate Defendant Ghosh’s general responsibility to manage the provision 

of medical services at Stateville Correctional Center. 

B. Defendant Carter was Personally Involved in the Delay and Denial of Mr. 

Ford’s Medical Treatment. 

As to Defendant Carter, Mr. Ford adequately pleads his personal involvement in the 

denial of medical care to Mr. Ford. First, Defendant Carter adopted and implemented an express 

policy of voiding all orders made by his predecessor. (Compl. ¶ 45.) In furtherance of that 

policy, Defendant Carter voided the order for Mr. Ford’s treatment, only to later reinstate the 

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order after an extended delay. (Compl. ¶¶ 45, 57.) The very fact that Defendant Carter reviewed 

the order referring Mr. Ford to the UIC Pain Clinic is more than enough to support Mr. Ford’s 

contention that that Defendant Carter must have been aware of the order, and therefore Mr. 

Ford’s serious medical need. Furthermore, as illustrated by Exhibit S to the Complaint, 

Defendant Carter was aware on September 23, 2011 that Mr. Ford “never got referred to [the 

UIC] pain center in Jan 2011 as documented by Dr. Ghosh.” (Compl. Ex. S.) Defendant 

Carter’s actions deliberately and predictably resulted in an extended delay in Mr. Ford’s 

treatment, during which time his condition continued to worsen. (Compl. ¶¶ 52, 54, 57.) 

Second, Defendants’ repeatedly mischaracterize the allegations in Mr. Ford’s Complaint 

by asserting that Mr. Ford visited the UIC Pain Clinic on December 6, 2011. (Mot. at 9, 10.) 

Mr. Ford did not do so. (Comp. ¶¶ 59-64.) As alleged in Mr. Ford’s complaint, not only was 

Mr. Ford denied the scheduled treatment at the UIC Pain Clinic on December 6, 2011, but 

Defendant Carter was personally involved in the denial. (Compl. ¶ 67.) As Mr. Ford has 

alleged, Superintendant Pounovich stated to Defendant Grievance Officer McBee that Defendant 

Carter personally overrode Mr. Ford’s permit for medical restraints, without which Mr. Ford 

could not be transported for treatment. (Compl. ¶ 67.) Defendants’ continued unwillingness or 

inability to understand the prolonged and repeated denial of treatment to Mr. Ford is the very 

reason this litigation is now before this Court. 

C. Latonya Williams was Personally Involved in the Delay and Denial of Mr. 

Ford’s Medical Treatment. 

As to Defendant Williams, Mr. Ford has also adequately alleged that she was aware of 

and was deliberately indifferent to Mr. Ford’s medical needs. (Compl. ¶¶ 23, 25, 40, 42.) Not 

only was Defendant Williams aware of Mr. Ford’s condition, the repeated failure to provide Mr. 

Ford with permits as ordered, the continued prescribing of pain medicines which were known to 

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cause Mr. Ford’s stomach to bleed, and the delay in his treatment at the UIC Pain Clinic, but she 

perpetuated that denial by failing to act to remedy the denial of care. (Compl. ¶¶ 23, 25, 40, 42.) 

Defendants do not dispute that there was any difference of medical opinion as to the necessity of 

any of the measures Defendant Williams did order. For example, Defendants do not dispute that 

Mr. Ford actually needed the back braces, ice, pain medicine that Williams ordered. (Compl. ¶¶ 

37, 40, 42.) Defendants only dispute that Defendant Williams was responsible for actually 

following through on her decisions or those of the medical director. 

Defendants are incorrect that Defendant Williams’ decision to order a back brace is 

enough to insulate her from her repeated failure to obtain the permits she recognized Mr. Ford 

required. (Mot. at 7.) Defendants’ own case law establishes that simply handing off an order is 

not sufficient to insulate a medical official from liability. Flournoy, 2012 U.S. Dist. LEXIS 

103388, at *25. 

II. Defendants are not Entitled to Qualified Immunity because Defendants 

Violated Mr. Ford’s Clearly Established Constitutional Rights. 

Defendants are not entitled to raise qualified immunity for three reasons. 

First, once again, Defendants misstate the governing legal standard. Although 

Defendants argue that Mr. Ford “was not ignored and left with no treatment,” the standard of 

care in fact is not whether an inmate was ignored. (Mot. at 13.) Instead, the well-settled law in 

this Circuit is that an inmate need not show that he was completely ignored to state a claim for 

deliberate indifference of medical need. Adams v. Detella, No. 98-1613, 2000 U.S. App. LEXIS 

30189, at *10 (7th Cir. 2000) (“[p]risoners are not required to show that they were completely 

ignored by prison medical staff to demonstrate deliberate indifference”); Allen v. Wexford Health 

Sources, Inc., No. 11 C 3834, 2011 U.S. Dist. LEXIS 66537, *3-4 (N.D. Ill. June 17, 2011) (“the 

fact that a prisoner received some medical treatment does not necessarily defeat his claim.”) 

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(citing Greeno v. Daley, 414 F.3d 645, 654 (7th Cir. 2005). Defendants’ rote recitation of case 

law, evidently pulled from a brief addressing facts in no way relevant to the facts here, fails to 

overcome Mr. Ford’s well pleaded complaint nor does it override Defendants Wexford, Ghosh, 

Carter, and William’s liability in their official capacity. 

Second, again, Defendants misstate the allegations contained in Mr. Ford’s Complaint. 

Although Defendants note in their brief that “[w]hile the denial of dental care may classify as a 

constitutional violation . . . Plaintiff cannot demonstrate that the Wexford Defendants violated a 

clearly established constitutional right.” (Mot. at 13.) But this not a case about dental care. 

Defendants’ failure to engage with the facts of Mr. Ford’s Complaint is indicative of their overall 

failure to address his serious medical need. 

Third, Defendants have failed to establish that they are entitled to qualified immunity as a 

matter of law. In determining whether qualified immunity applies, the court considers whether 

the plaintiff has asserted a violation of a federal constitutional right and whether the 

constitutional standards allegedly violated were clearly established at the time in question. Roe 

v. Elyea, 634 F.3d 843, 858 (7th Cir. 2011). Mr. Ford’s right to adequate medical care and 

treatment was clearly established at all times relevant to this action. Id. Defendants’ repeated 

failure to treat Mr. Ford’s condition or his pain violated his rights under the Eight Amendment. 

See, e.g. Roe, 631 F.3d at 861 (denying Defendant medical director’s invocation of qualified 

immunity); McGowan v. Hulick, 612 F.3d 636, 640 (7th Cir. 2010) (delay in treatment may 

constitute deliberate indifference in violation of the Constitution if the delay exacerbated an 

injury or unnecessarily prolonged an inmate’s pain); Jones v. Simek, 193 F.3d 485 (7th Cir. 

1999) (plaintiff stated claim for deliberate indifference where plaintiff alleged defendants’ 

refusal to treat his chronic pain). To the extent Defendants assert any particularized entitlement 

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to the defense, Defendants present a question of fact, not appropriate for a motion to dismiss. 

See, e.g., Roe, 631 F.3d at 853 (considering application of qualified immunity in a motion for 

judgment as a matter of law). 

III. Defendants Wexford, Dr. Ghosh, and Dr. Carter are Liable in Their Official 

Capacities. 

Defendants are mistaken that they may not be sued in their official capacities. A plaintiff 

may bring official capacity claims seeking injunctive relief. Taylor v. Wexford Health Services, 

Inc., No 11 C 7386, 2012 U.S. Dist. LEXIS 9260, *8 (N.D. Ill. Jan 26, 2012) (citing Ex Parte 

Young, 209 U.S. 123 (1908). Mr. Ford has sued Defendants Wexford, Ghosh and Carter in their 

official capacity seeking injunctive relief. (Compl. at 18.) To the extent Mr. Ford is seeking 

monetary relief, he does so only as part of his claims against Defendants in their individual 

capacities. 

Furthermore, Mr. Ford has made detailed allegations regarding the existence of multiple 

policies and practices adopted by Defendants Wexford, Ghosh, and Carter as cost saving 

measures, which resulted in the deprivation of medical care and a violation of his constitutional 

rights. Mr. Ford has alleged the following policies and practices: 

 Delaying scheduling medical appointments. (Compl. ¶¶ 20, 22, 28-29, 51.) 

 Delaying the filling and renewal of prescriptions. (Compl. ¶¶ 31, 37, 42, 47.) 

 Delaying the issuance of permits. (Compl. ¶¶ 20, 22, 28-29, 31, 37, 40, 42, 47, 52, 56.) 

 Delaying the provision of treatment at third party providers (Compl. ¶¶ 37, 40, 47.) 

 Defendant Carter’s express policy of voiding all of Dr. Ghosh’s orders. (Compl. ¶¶ 45-

46.) 

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Thus, Mr. Ford has adequately alleged facts sufficient to show that Defendants Wexford, 

Ghosh, and Carter instituted and maintained policies which directly caused the deprivation of 

constitutionally adequate medical to Mr. Ford and are liable in their official capacities. 

CONCLUSION 

 For all the foregoing reasons, this Court should deny Defendants Wexford, 

Ghosh, Carter and Williams’ Motion to Dismiss the Amended Complaint. 

Dated: December 14, 2012 Respectfully submitted, 

 HUNDLEY LYNN FORD, JR. 

 

__/s Terrence J. Truax_________ 

 One of His Attorneys 

 Terrence J. Truax 

Molly M. Powers 

JENNER & BLOCK LLP

353 North Clark Street 

Chicago, Illinois 60654-3456 

(312) 222-9350 

 

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CERTIFICATE OF SERVICE

 On December 14, 2012, I, Molly M. Powers, an attorney, caused a true and correct copy 

of the foregoing Plaintiff’s Memorandum of Law in Opposition to Defendants’ Motion to 

Dismiss to be served on the following counsel of record via email, due to the inaccessibility of 

the ECF/PACER system in the United States District Court for the Northern District of Illinois 

Eastern Division as result of system maintenance, and on December 16, 2012 caused a true and 

correct copy to be served on the following counsel of record via the ECF/PACER system in the 

United States District Court for the Northern District of Illinois Eastern Division: 

James C. Vlahakis 

Hinshaw & Culbertson, LLP 

222 North LaSalle, Suite 300 

Chicago, Illinois 60601 

(p) 312-704-3715 

(f) 312-704-3001 

jvlahakis@hinshawlaw.com 

Counsel for Defendant Wexford Health Sources, Inc., 

Parthasarathi Ghosh, Imhotep Carter, and Latonya Williams 

Dated: December 16, 2012 __/s Molly M. Powers______

 

 

JENNER & BLOCK LLP

353 North Clark Street 

Chicago, Illinois 60654 

(p) 312-222-9350 

(f) 312-840-7703 

mpowers@jenner.com 

Counsel for Plaintiff, 

Hundley Lynn Ford, Jr. 

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