The Seventh Circuit Court of Appeals affirmed summary judgment in favor of Hancock County Jail officials in a case involving claims of deliberate indifference to a detainee's medical needs following post-surgical complications.
In *Zemlick v. Burkhart*, decided Jan. 22, 2026, the appeals court upheld the U.S. District Court for the Southern District of Indiana's ruling dismissing Nicholas Zemlick's civil rights lawsuit against Hancock County Sheriff Brad Burkhart and two jail personnel.
The case arose from events in August 2020, when Zemlick was detained at the Hancock County Jail in Indiana. While in custody, Zemlick underwent elective abdominal surgery at an off-site medical facility. Following the procedure, he returned to the jail to recover.
During his recovery period at the jail, Zemlick developed a serious infection and became severely ill. Jail officials ultimately transported him to a hospital for emergency surgery to treat the infection. According to the court record, Zemlick made a full recovery from both the original procedure and the subsequent infection.
Zemlick filed suit under 42 U.S.C. § 1983, the federal civil rights statute that allows individuals to sue government officials for constitutional violations. He claimed that jail personnel were deliberately indifferent to his medical needs in violation of his due process rights under the Fourteenth Amendment.
The lawsuit included both individual claims against specific jail officers and a *Monell* claim against the Sheriff. Under *Monell v. Department of Social Services* (1978), municipalities and their officials can be held liable for constitutional violations when such violations result from official policy or custom. Zemlick alleged that Sheriff Burkhart failed to ensure adequate medical resources at the jail facility.
The legal standard for deliberate indifference in the jail context requires more than negligence or medical malpractice. Under Fourteenth Amendment jurisprudence, pretrial detainees must show that jail officials acted with deliberate indifference to serious medical needs. This standard protects detainees who have not been convicted of crimes but are held pending trial.
District Judge Matthew P. Brookman granted summary judgment in favor of all defendants, finding that Zemlick's claims failed to meet the required legal standards. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.
On appeal, Circuit Judge Kolar, writing for a three-judge panel that also included Circuit Judges St. Eve and Lee, affirmed the district court's ruling. The Seventh Circuit found that Zemlick's claims failed on multiple grounds.
The appeals court determined that some of Zemlick's claims failed on the merits, meaning they did not satisfy the legal requirements for deliberate indifference. Other claims were found to be waived, likely due to procedural failures in how they were presented to the courts.
Additionally, the court found that qualified immunity barred some claims against the individual defendants. Qualified immunity protects government officials from civil liability when their conduct does not violate clearly established statutory or constitutional rights that a reasonable person would have known about.
The case highlights ongoing challenges in prisoner medical care litigation. Courts must balance the constitutional rights of detainees to receive adequate medical care with recognition that not every instance of suboptimal treatment rises to the level of a constitutional violation.
For deliberate indifference claims to succeed, plaintiffs typically must show both an objectively serious medical need and that officials were subjectively aware of the risk but disregarded it. The fact that Zemlick received emergency treatment for his infection and made a full recovery likely complicated his ability to demonstrate deliberate indifference.
The ruling also addresses *Monell* liability, which requires showing that constitutional violations resulted from municipal policy, custom, or practice rather than isolated actions by individual employees. Establishing such institutional liability often requires evidence of widespread problems or official policies that caused the constitutional harm.
While the specific details of the Seventh Circuit's reasoning are not fully available in the partial record, the affirmance suggests the court found insufficient evidence to support either the individual deliberate indifference claims or the institutional *Monell* claim against the Sheriff.
The decision reflects broader trends in federal courts' handling of jail conditions litigation, where courts often defer to jail administrators' medical judgments unless there is clear evidence of deliberate disregard for serious medical needs.
For jail administrators and medical providers, the ruling reinforces that providing some medical care, even if imperfect, may satisfy constitutional minimums. For detainees and their advocates, it underscores the high evidentiary bar required to prove deliberate indifference claims.
The case was argued before the Seventh Circuit on Sept. 9, 2025, with the decision issued on Jan. 22, 2026. The original lawsuit was filed in 2022 and carried the district court case number 1:22-cv-02319.