The Seventh Circuit Court of Appeals affirmed a district court's summary judgment ruling in favor of prison officials at East Moline Correctional Center in *Jaryan Gills v. Robert Hamilton* (7th Cir. 2026), rejecting an inmate's claims that his constitutional rights were violated through inadequate living conditions and medical care.
Jaryan Gills sued prison officials under 42 U.S.C. § 1983, alleging Eighth Amendment violations based on his cell conditions and medical treatment following an assault by another inmate in February 2020. The case arose after Gills was punched in the face and suffered a broken arm during an incident in the common area at East Moline Correctional Center.
According to the court opinion, Gills was taken by ambulance to the emergency room and underwent two operations over the following week. Surgeons replaced part of his elbow, repaired a ligament, and inserted pins to stabilize the joint. However, Gills alleged that upon his return to the facility, he was subjected to deplorable living conditions.
The plaintiff claimed he was forced to live in what he characterized as "wretched conditions" without access to a sink or toilet in his cell. Additionally, Gills alleged that several guards refused to allow him to use bathroom facilities for extended periods, compounding his distress. He also claimed that medical care was frequently delayed or substandard, affecting his recovery from the assault injuries.
Gills named prison doctor Robert Hamilton and other officials as defendants in his federal civil rights lawsuit. The case was initially filed in the U.S. District Court for the Central District of Illinois under case number 4:21-cv-4011, with Judge Colleen R. Lawless presiding.
The district court granted defendants' motions for summary judgment, finding insufficient evidence to support Gills's constitutional claims. The lower court determined that the evidence did not establish that prison officials acted with deliberate indifference to Gills's health and safety.
On appeal, a three-judge panel of the Seventh Circuit consisting of Chief Judge Brennan and Circuit Judges Kirsch and Jackson-Akiwumi heard oral arguments on Sept. 11, 2025. Circuit Judge Kirsch wrote the opinion for the court, which was decided on Jan. 15, 2026.
Writing for the unanimous panel, Circuit Judge Kirsch explained that the court must view the contested facts in the light most favorable to Gills at the summary judgment stage, citing *Torres v. Madrid* (S. Ct. 2021). However, even under this standard, the appeals court found that Gills could not demonstrate that defendants acted unreasonably given their knowledge of the circumstances.
The Eighth Amendment prohibits cruel and unusual punishment, which includes deliberate indifference to serious medical needs and inhumane conditions of confinement. To prevail on such claims, prisoners must show both that the deprivation was sufficiently serious and that prison officials acted with deliberate indifference.
For conditions of confinement claims, courts analyze whether the conditions pose an unreasonable risk of serious damage to health and whether officials knew of and disregarded that risk. The subjective component requires showing that officials were aware of facts from which they could infer a substantial risk of serious harm.
Regarding medical care claims, prisoners must establish that they had a serious medical need and that prison officials were deliberately indifferent to that need. Deliberate indifference requires more than negligence or inadvertent failure to provide care.
The Seventh Circuit's affirmance suggests that while Gills's allegations paint a concerning picture of his post-assault treatment, the evidence was insufficient to meet the demanding legal standards for Eighth Amendment violations. The court likely found that defendants' actions, while perhaps suboptimal, did not rise to the level of constitutional violations given the information available to prison staff.
This decision reflects the ongoing challenges inmates face in successfully litigating conditions of confinement and medical care cases. Federal courts generally defer to prison administrators' judgment regarding security and operational concerns, requiring clear evidence of deliberate indifference to constitutional rights.
The ruling also highlights the difficulty of proving subjective deliberate indifference, as plaintiffs must demonstrate not just that conditions were poor, but that officials consciously disregarded known risks to inmate health and safety.
Prison reform advocates often point to cases like *Gills* as examples of the high burden inmates face when seeking redress for allegedly unconstitutional treatment. The decision reinforces the Seventh Circuit's typically deferential approach to prison administration while maintaining constitutional minimums for inmate treatment.
The case adds to the body of Seventh Circuit precedent addressing the boundaries of acceptable prison conditions and medical care standards. While the specific details of what evidence was presented remain limited in the available opinion excerpt, the outcome suggests that courts continue to set a high bar for finding constitutional violations in prison settings.
Neither party has indicated whether they plan to seek further review of the decision. The ruling stands as the final resolution of Gills's claims against the East Moline Correctional Center officials.