Anderson

DIN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF ILLINOIS

LAMAR ANDERSON,

Plaintiff,

v. Case No. 22-CV-00221-SPM

MOHAMMED SIDDIQUI, et al.,

Defendants.

MEMORANDUM AND ORDER

McGLYNN, District Judge:

Pending before the Court are two Motions for Summary Judgment—one filed

by Defendants Mohammed Siddiqui, M.D.; Reynal Caldwell, M.D.; and Michael

Moldenhauer, N.P. (Doc. 62), and the other filed by Defendants Angela Crain and

Amy Lang (Doc. 56). Having been fully informed of the issues presented, both Motions

for Summary Judgment are GRANTED.

RELEVANT FACTUAL AND PROCEDURAL BACKGROUND

Pro se Planintiff Lamar Anderson, an inmate currently incarcerated at

Western Illinois Correctional Center, filed this action on January 26, 2022. (See Doc.

1; Doc. 56, p. 1). He brings multiple Eighth Amendment claims pursuant to 42 U.S.C.

§ 1983 alleging inadequate treatment of his eczema while incarcerated at Menard

Correctional Center (“Menard”). (Docs. 1, 8). Following preliminary review under 28

U.S.C. § 1915A, the Court consolidated Anderson’s claims into a single Eighth

Amendment deliberate indifference claim against Defendants Siddiqui, Caldwell,

Moldenhauer, Crain, and Lang for failing to provide adequate treatment for his

eczema. (Doc. 8, p. 3).

According to the operative Complaint, Anderson developed eczema while

incarcerated at Stateville Correctional Center. (Doc. 1, p. 3). After he was transferred

to Menard Correctional Center, he began to experience difficulties obtaining the

medications previously prescribed for his condition. (Id., pp. 3–5). He submitted

multiple grievances during his time at Menard regarding the adequacy of his medical

treatment for his eczema. (See id., Exs. A, B, C, E). Although Anderson eventually

received prescriptions for Benadryl and a topical ointment, he alleges that refills were

not consistently provided in a timely manner and that follow-up care was delayed.

(Id., pp. 3–5). Anderson’s interactions with Defendants regarding the treatment of

his skin condition form the basis of his deliberate indifference claim.

Defendants filed two Motions for Summary Judgment on November 13, 2023,

one filed by Caldwell and Siddiqui and one by Lang and Crain. (Doc. 34, 37). Both

Motions argued that Anderson had not properly exhausted his administrative

remedies as is required by Prison Litigation Reform Act, 42 U.S.C. § 1997 et seq.

(“PLRA”). (See Docs. 34, 37). The Court denied both Motions on August 21, 2024. (Doc.

49).

Defendants Crain and Lang then filed the present Motion for Summary

Judgment on July 23, 2025 and Siddiqui, Caldwell, and Moldenhauer filed their own

Motion for Summary Judgment three months later. (Docs. 56, 62). Anderson

responded in opposition to both Motions. (Docs. 58, 74). Only Siddiqui, Caldwell, and

Moldenhauer submitted a Reply. (Docs. 75). Accordingly, both Motions for Summary

Judgment are ripe for review.

APPLICABLE LAW AND LEGAL STANDARDS

The Court shall grant summary judgment “if the movant shows that there is

no genuine dispute as to any material fact and the movant is entitled to judgment as

a matter of law.” Spurling v. C & M Fine Pack, Inc., 739 F.3d 1055, 1060 (7th Cir.

2014) (quoting FED. R. CIV. P. 56(a)). Once the moving party has set forth the basis

for summary judgment, the burden then shifts to the nonmoving party who must go

beyond mere allegations and offer specific facts showing that there is a genuine issue

of fact for trial. FED. R. CIV. P. 56(e); see Celotex Corp. v. Catrett, 477 U.S. 317, 322–

23 (1986). Stated another way, the nonmoving party must offer more than

“[c]onclusory allegations, unsupported by specific facts,” to establish a genuine issue

of material fact. Payne v. Pauley, 337 F.3d 767, 773 (7th Cir. 2003) (citing Lujan v.

Nat’l Wildlife Fed’n, 497 U.S. 871, 888 (1990)).

In determining whether a genuine issue of fact exists, the Court must view the

evidence and draw all reasonable inferences in favor of the party opposing the motion.

Bennington v. Caterpillar Inc., 275 F.3d 654, 658 (7th Cir. 2001); see also Anderson v.

Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). “A genuine issue of material fact arises

only if sufficient evidence favoring the nonmoving party exists to permit a jury to

return a verdict for that party.” Faas v. Sears, Roebuck & Co., 532 F.3d 633, 640–41

(7th Cir. 2008) (quoting Springer v. Durflinger, 518 F.3d 479, 483 (7th Cir. 2008)).

The non-movant cannot simply rely on its pleadings; the non-movant must present

admissible evidence that sufficiently shows the existence of each element of its case

on which it will bear the burden of proof at trial. Midwest Imports., Ltd. v. Coval, 71

F.3d 1311, 1317 (7th Cir. 1995) (citing Serfecz v. Jewel Food Stores, 67 F.3d 591, 596

(7th Cir. 1995); Greater Rockford Energy & Tech. Corp. v. Shell Oil Co., 998 F.2d 391,

394 (7th Cir. 1993), cert. denied, 510 U.S. 1111 (1994); Celotex, 477 U.S. at 323–24).

ANALYSIS

The Eighth Amendment’s prohibition against cruel and unusual punishment

embodies “broad and idealistic concepts of dignity, civilized standards, humanity, and

decency.” Estelle v. Gamble, 429 U.S. 97, 102 (1976). Such prohibition requires that

the government provide “medical care for those whom it is punishing by

incarceration” and safeguards the prisoner against a lack of medical care that “may

result in pain and suffering which no one suggests would serve any penological

purpose.” Id. at 103. Accordingly, deliberate indifference to the “serious medical needs

of a prisoner constitutes the unnecessary and wanton infliction of pain forbidden by

the Constitution.” Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 828 (7th

Cir. 2009). However, a prisoner is entitled to “reasonable measures to meet a

substantial risk of serious harm”—not to demand specific care. Forbes v. Edgar, 112

F.3d 262, 267 (7th Cir. 1997).

Claims for deliberate indifference have an objective and a subjective

component. Gutierrez v. Peters, 111 F.3d 1364 (7th Cir. 1997). Thus, a plaintiff must

establish that he suffered from an objectively and sufficiently serious medical

condition and that the defendants actually knew of, but disregarded, a substantial

risk to his health. Cesal v. Moats, 851 F.3d 714, 721 (7th Cir. 2017). “Intentional

delays in medical care may constitute deliberate indifference, even if the inmate’s

medical condition is non-life threatening.” Id. at 722 (quoting Arnett v. Webster, 658

F.3d 742, 753 (7th Cir. 2011)). “A doctor’s choice of ‘easier and less efficacious

treatment’ for an objectively serious medical condition also may be sufficient but

‘mere disagreement with a doctor’s medical judgment’ is not enough to support an

Eighth Amendment violation.” Id. (first quoting Estelle, 429 U.S. at 104 n.10 then

quoting Berry v. Peterman, 604 F.3d 435, 441 (7th Cir. 2010)) (citation modified).

Additionally, it is well-settled that mere negligence is not enough to establish

a defendant’s deliberate indifference. See, e.g., Davidson v. Cannon, 474 U.S. 344,

347–48 (1986). In fact, even gross negligence is insufficient. King v. Kramer, 680 F.3d

1013, 1018 (7th Cir. 2012). Instead, deliberate indifference is comparable to criminal

recklessness. Thomas v. Blackard, 2 F.4th 716 (7th Cir. 2021) (citing King, 680 F.3d

at 1018). In the context of a deliberate indifference claim, “reckless describes conduct

so dangerous that the deliberate nature of the defendant’s actions can be inferred.”

Jackson v. Illinois Medi-Car, Inc., 300 F.3d 760, 765 (7th Cir. 2002) (citation

modified).

Meeting the subjective prong is more difficult in cases alleging inadequate

care. Without more, a “mistake in professional judgment cannot be deliberate

indifference.” Whiting v. Wexford Health Sources, Inc., 839 F.3d 658, 662 (7th Cir.

2016). The Seventh Circuit has explained:

By definition a treatment decision that’s based on professional judgment

cannot evince deliberate indifference because professional judgment

implies a choice of what the defendant believed to be the best course of

treatment. A doctor who claims to have exercised professional judgment

is effectively asserting that he lacked a sufficiently culpable mental

state, and if no reasonable jury could discredit that claim, the doctor is

entitled to summary judgment.

Id. (citing Zaya v. Sood, 836 F.3d 800, 805–06 (7th Cir. 2016)). This is in contrast to

a case “where evidence exists that the defendant knew better than to make the

medical decision that he did.” Id. (quoting Petties v. Carter, 836 F.3d 722, 731 (7th

Cir. 2016)) (citation modified). A medical professional’s choice of an “easier and less

efficacious treatment” can rise to the level of violating the Eighth Amendment only

where the treatment is known to be ineffective but is chosen anyway. Berry, 604 F.3d

at 441 (quoting Estelle, 429 U.S. at 104 n.10). The Seventh Circuit has “characterized

the standard as imposing a high hurdle on plaintiffs because it requires a ‘showing

as something approaching a total unconcern for the prisoner’s welfare in the face of

serious risks.’” Rosario v. Brawn, 670 F.3d 816, 821 (7th Cir. 2012) (quoting Collins

v. Seeman, 462 F.3d 757, 762 (7th Cir. 2006)).

The first question before the Court is whether Anderson’s eczema qualified as

a “serious” medical condition. For the purposes of an Eighth Amendment deliberate

indifference claim, a serious medical condition is “one that has been diagnosed by a

physician as mandating treatment or one that is so obvious that even a lay person

would easily recognize the necessity for a doctor’s attention.” Wynn v. Southward, 251

F.3d 588, 593 (7th Cir. 2001) (quoting Gutierrez, 111 F.3d at 1373). The Supreme

Court has noted that medical conditions far less critical than “life-threatening” are

sufficiently serious. Estelle, 429 U.S. at 107. In applying this principle, the Seventh

Circuit has held that an infected pilonidal cyst, minor lacerations, bruises, and

irritated eyes, and rheumatoid arthritis are all, independently, sufficiently serious.

See Gutierrez, 111 F.3d at 1370; Cooper v. Casey, 97 F.3d 914, 917–18 (7th Cir. 1996);

Arnett, 658 F.3d at 750. However, the Seventh Circuit put common colds, toes with

removed toenails, and mild asthma as being outside the ambit of “serious” medical

needs. See Gutierrez, 111 F.3d at 1372 (citing Gibson v. McEvers, 631 F.2d 95 (7th

Cir. 1980); Snipes v. DeTella, 95 F.3d 586, 591 n.1 (7th Cir. 1996), cert. denied, 519

U.S. 1126 (1997); Oliver v. Deen, 77 F.3d 156 (7th Cir. 1996)).

While the Seventh Circuit has not specifically addressed whether eczema is a

serious medical condition, this Court has previously held on multiple occasions that

painful rashes requiring “multiple creams, steroids, and antihistamines” were

“objectively serious.” See Boclair v. Wills, No. 21-CV-00289-SPM, 2024 WL 3673136,

at *8 (S.D. Ill. Aug. 6, 2024) (citing Parada v. Wexford Health Sources, Inc., No. 19-

CV-00056-SPM, 2023 WL 3918957, at *4 (S.D. Ill. June 9, 2023)); see also Franklin v.

Gladson, No. 14-CV-1102-JPG-RJD, 2018 WL 481882, at *3 (S.D. Ill. Jan. 2, 2018)

(finding scabies to be objectively serious, particularly given it was treated with a

prescription ointment.). Here, the record shows that Anderson’s eczema was treated

with multiple antihistamines and topical steroids over several years, including

Benadryl, Allegra, Zyrtec, Fluocinonide, and various steroid creams. (See Doc. 56, Ex.

A, 19:4–20:17; id., Exs. F, H, I, T,; Ex. U; Ex. W; Ex. X; Doc. 63, Ex. E, pp. 366, 448,

450; Doc. 56, Ex. A, 35:20–36:12; Ex. H; Ex. K; Ex. M; Ex. O; Ex. R; Ex. W; Ex. X).

In his deposition, Anderson claimed that his condition involves two different

kinds of flare-ups on his skin: one in which it feels as though something is “coming

out of [his] skin” and the other in which he has dry rashes on different parts of his

body. (Doc. 56, Ex. A, 21:6–13). He stated that the Benadryl and topical steroids were

effective in managing his skin condition. (Id., Ex. A, 20:21–21:2, 59:1–3, 66:17–19).

Based on this record, the Court concludes that Anderson’s eczema constituted a

sufficiently serious medical need under the first prong of the deliberate indifference

standard. See Cesal, 851 F.3d at 721.

The Court next turns to the question of whether each of the medical provider

Defendants were deliberately indifferent to Anderson’s eczema. Since Anderson’s

Complaint broadly accuses the Defendants of deliberate indifference toward his skin

condition, to assess potential liability, the Court must evaluate the undisputed

conduct of each Defendant individually.

I. Defendant Siddiqui

Dr. Mohammed Siddiqui served as Medical Director at Menard from June 12,

2017 through August 2021. (Doc. 63, Ex. B, ¶ 2). Anderson’s allegations against him

span from April 17, 2017, to July 28, 2021. (Id., Ex. A, 98:6–16). During that period,

Dr. Siddiqui evaluated Anderson on multiple occasions, including several visits

specifically addressing his eczema and associated itching.

When Anderson transferred to Menard in December 2016, he had an active

prescription for Benadryl that expired shortly thereafter. (See id., Ex. E, pp. 2, 4–6,

9–10). On April 17, 2017, Dr. Siddiqui first evaluated Anderson for complaints related

to eczema. (Id., Ex. E, p. 14). Anderson reported that Benadryl was the only

medication that relieved his itching and that he had been taking it for approximately

two years. (Id.). Dr. Siddiqui renewed the prescription, ordering Benadryl 25 mg twice

daily for three months. (Id., Ex. E, pp. 14, 126).

On November 20, 2017, Anderson again visited Dr. Siddiqui with complaints

related to his chronic eczema. (Doc. 63, Ex. E, pp. 25, 139). Dr. Siddiqui observed

lesions on Anderson’s torso to be consistent with lichen planus and prescribed

Benadryl 25 mg twice daily for six months, along with a topical steroid (triamcinolone

0.1% cream) to be used as needed. (Id.). Anderson returned to Dr. Siddiqui on May

14, 2018 and reported persistent itchiness; Dr. Siddiqui observed eczematous lesions

on his torso. (Id., Ex. B, ¶ 26). The two discussed continuing Benadryl and

triamcinolone, and Dr. Siddiqui prescribed both medications for one year. (Id., Ex. E,

pp. 46, 151).

On August 22, 2018, Dr. Siddiqui evaluated Anderson primarily for elevated

blood pressure. (Id., Ex. E, pp. 48, 154). Because of Anderson’s hypertension, Dr.

Siddiqui initiated Lopressor (metoprolol), a medication used to treat high blood

pressure, and discontinued Benadryl. (Id.). According to Dr. Siddiqui, Benadryl can

interfere with Lopressor’s metabolism and increase the risk of adverse effects. (Id.,

Ex. B, ¶ 29). Given Anderson’s elevated blood pressure, Dr. Siddiqui elected to trial

the antihypertensive medication without Benadryl. (Id.). Anderson disagreed with

that decision but provided no medical evidence disputing Dr. Siddiqui’s rationale.

(Doc 74, ¶ 26; Doc. 75, ¶ 26).

On October 31, 2018, Anderson once again returned to Siddiqui with

complaints of generalized skin lesions. (See Doc. 63, Ex. E, pp. 51, 156). Dr. Siddiqui

assessed the lesions as likely lichen planus and noted that Benadryl had been

effective for itching. (Id.). Because Anderson’s blood pressure was normal, and he

appeared to not be experiencing adverse effects from Lopressor, Siddiqui re-

prescribed Benadryl and referred Anderson for consideration of a skin biopsy. (Id.,

Ex. E, pp. 51, 156; Ex. B, ¶¶ 29, 30).

On May 28, 2019, Dr. Siddiqui documented that Anderson’s eczema had

improved with steroid treatment and renewed triamcinolone. (Id., Ex. E, p. 63). On

July 22, 2019, Anderson again sought Benadryl for treatment for eczema. (Id., Ex. E,

pp. 66, 168; Ex. B, ¶ 37). The medical note reflects that he reported improvement in

itching while on Benadryl and Dr. Siddiqui prescribed Benadryl 25 mg twice daily for

three months. (Id., Ex. E, pp. 66, 168). During a November 27, 2019, chronic clinic

visit, Dr. Siddiqui noted Anderson’s history of eczema and generalized lichenoid

lesions, renewed Benadryl and triamcinolone and again referred Anderson for a

biopsy. (Id., Ex. E, pp. 111–12, 176).

Later visits in 2020 and 2021 primarily addressed hypertension management,

abnormal laboratory results, headaches, and an evaluation of a longstanding scalp

lesion. (Id., Ex. E, pp. 92, 100–01, 117–18, 196, 212, 214, 307). The record reflects that

eczema was not discussed at those visits. (Id., Ex. B, ¶¶ 42, 44, 47). Dr. Siddiqui’s

final documented encounter with Anderson occurred on July 28, 2021, shortly before

he left his position at Menard. (Id., Ex. E, p. 307; id., Ex. B, ¶ 48).

In sum, the record shows that Dr. Siddiqui repeatedly evaluated Anderson for

eczema and related itching, prescribed medications including Benadryl, and renewed

those prescriptions on a regular basis. Although he temporarily discontinued

Benadryl due to concerns about a potential interaction with an antihypertensive

medication, he reinitiated the medication once Anderson’s blood pressure stabilized.

Additionally, Dr. Siddiqui referred Anderson for further dermatologic evaluation on

multiple occasions.

Anderson asserts that Dr. Siddiqui deprived him of the Benadryl necessary to

treat his eczema. In his deposition, Anderson identified only one instance—between

August 22, 2018, and October 31, 2018—when Dr. Siddiqui discontinued the

medication. (See id., Ex. A, 105–06; id., Ex. E, pp. 48, 51). As discussed supra, Dr.

Siddiqui made this decision due to concerns about Anderson’s elevated blood pressure

and elected to discontinue Benadryl because of a potential interaction with Lopressor.

While Anderson disagreed with the decision, believing it unrelated to his condition,

the record reflects that Dr. Siddiqui’s determination was grounded in medical

judgment, as he believed Benadryl could interfere with Lopressor’s effectiveness and

increase the risk of adverse effects. (Id., Ex. B, ¶ 29).

The Seventh Circuit has stated that “[o]ne thing which has long been clear in

our Eighth Amendment cases is that the amendment is not coterminous with a

medical malpractice claim.” Forbes, 112 F.3d at 266 (citing Bryant v. Madigan, 84

F.3d 246 (7th Cir. 1996); Oliver, 77 F.3d 156; Snipes, 95 F.3d 586). Additionally,

prisoners are “not entitled to the best care possible” but rather “to reasonable

measures to meet a substantial risk of serious harm.” Id. at 267. When a prisoner

sought “specific treatment and foolproof protection from infection,” the Seventh

Circuit stated that “the Eighth Amendment does not provide her with either.” Id. at

266 (citation modified).

Here, Siddiqui’s decision was made in a context where he was aware of

Anderson’s prior use of Benadryl to treat his symptoms. Although Dr. Siddiqui did

not yet know whether other treatments like topical steroids would be effective, he

instructed Anderson to return if his symptoms worsened, and he adjusted treatment

accordingly when they did. (Id., Ex. A, 49:9–16; id., Ex. B, ¶ 29; id., Ex. E, p. 63).

Anderson also conceded that no medical professional had told him his condition

worsened due to treatment provided by Dr. Siddiqui. (Id., Ex. A, 99:23–100:2). “In the

Eighth Amendment context, medical professionals receive a great deal of deference

in their treatment decisions.” Wilson v. Wexford Health Sources, Inc., 932 F.3d 513,

519 (7th Cir. 2019). There is only a Constitutional violation if “no minimally

competent professional would have so responded under those circumstances.” Id.

(citing Collignon v. Milwaukee County, 163 F.3d 982, 989 (7th Cir. 1997)).

Based on the record, the Court concludes that Dr. Siddiqui’s decisions reflected

medical judgment rather than deliberate indifference. When Siddiqui temporarily

discontinued Benadryl, he advised Anderson to return if his condition worsened, and

when it did, Siddiqui corrected course. See Arnett, 658 F.3d at 754 (“[a] prison

physician cannot simply continue with a course of treatment that he knows is

ineffective in treating the inmate’s condition.”). Therefore, even when construing the

evidence in Anderson’s favor, no reasonable jury could find that Dr. Siddiqui acted

with deliberate indifference, meaning that summary judgment shall be granted for

Dr. Siddiqui.

II. Defendant Caldwell

The Court now evaluates the undisputed evidence concerning Dr. Reynal

Caldwell and his role in Anderson’s medical treatment. Dr. Caldwell was employed

by Wexford Health Sources as a Traveling Medical Director from May 18, 2015,

through August 8, 2024. (Doc. 63, Ex. C, ¶ 2). Between 2018 and 2020, he provided

medical services at various correctional facilities in Southern Illinois on an as-needed

basis including Menard. (Id.). Anderson testified that his claims against Dr. Caldwell

relate to the period from December 21, 2018, through February 11, 2020, in which he

visited Dr. Caldwell four times. (Id., Ex. A, 97:21–98:4).

Dr. Caldwell’s first encounter with Anderson occurred on December 21, 2018,

during a General Medicine Chronic Clinic visit. (Id., Ex. C, ¶ 28). The purpose of the

appointment was to evaluate Anderson for a possible skin biopsy related to his

eczema. (Id., Ex. E, pp. 56, 107–08, 159). After examining Anderson’s skin, Dr.

Caldwell concluded that the presentation was consistent with eczema and that a

punch biopsy was not clinically indicated. (Id., Ex. C, ¶ 28). He noted that Anderson’s

symptoms responded to Benadryl and prescribed Benadryl 25 mg twice daily for six

months. (Id., Ex. E, pp. 56, 107–08, 159).

Nearly one year later, Anderson was again referred to Dr. Caldwell for further

evaluation, including consideration of a biopsy due to his history of eczema, pruritus,

and generalized lichenoid lesions. (Doc. 63, Ex. E, pp. 111–12, 176). Based on that

referral, Dr. Caldwell saw Anderson on December 10, 2019. (Id., Ex. E, pp. 71, 178).

At that visit, Dr. Caldwell prescribed Kenalog (triamcinolone), a topical

corticosteroid, and Zyrtec, an antihistamine, for a ninety-day period, and instructed

Anderson to return in thirty days. (Id.). Dr. Caldwell testified that his examination

again led him to conclude that a punch biopsy was not medically necessary. (Id., Ex.

C, ¶ 37). Anderson requested additional testing because he was frustrated with

recurring flare-ups and what he viewed as lapses in follow-up care. (Doc. 74, ¶ 37).

Anderson identified no evidence suggesting that a biopsy was required, and Dr.

Caldwell continued to maintain that the condition was consistent with eczema and

manageable with medication. (Doc. 63, Ex. C, ¶ 37; Doc. 75, ¶ 37). At a follow-up

appointment on January 7, 2020, Dr. Caldwell noted that Anderson’s rash was

controlled with Kenalog, and no new medications or further treatment were ordered.

(Doc. 63, Ex. E, p. 73).

On January 29, 2020, Dr. Caldwell evaluated Anderson for an unrelated

concern involving a lump on his lip, which was removed two weeks later. (Doc. 63,

Ex. E, pp. 77, 79). Anderson’s eczema was not addressed during either the evaluation

or the removal visit, and Dr. Caldwell testified that this was his final encounter with

Anderson. (Id., Ex. C, ¶¶ 39, 40).

In summary, the undisputed evidence shows that Dr. Caldwell saw Anderson

on several occasions for eczema-related complaints, assessed his condition as

consistent with eczema, prescribed antihistamines and topical steroids, and declined

to perform a biopsy based on his clinical judgment. Accordingly, the Court does not

find Caldwell’s behavior tantamount to deliberate indifference.

While Anderson’s primary criticisms of Dr. Caldwell involved delays in

renewing his prescriptions, he acknowledged that those issues couldn’t be blamed on

Dr. Caldwell. (Doc. 63, Ex. A, 27:5–28:13, 105:5–8). When asked whether he believed

Dr. Caldwell had done everything he could to ensure that Anderson’s medications

would be renewed and provided after they expired, Anderson answered yes. (Id., Ex.

A, 55:4–8). Anderson’s only remaining criticism was that Dr. Caldwell did not perform

a punch biopsy. (Doc. 63, Ex. A, 27:5–13). However, a prisoner’s disagreement with a

physician’s chosen course of treatment, standing alone, does not establish deliberate

indifference under the Eighth Amendment. Snipes, 95 F.3d at 591. Dr. Caldwell

determined through visual examination that Anderson’s condition was consistent

with eczema and that a punch biopsy was not medically necessary. (Doc. 63, Ex. C, ¶

28) Accordingly, the Court finds that judgment medically reasonable.

When considering the undisputed facts of this matter in light of circuit

precedent, it is clear that Dr. Caldwell’s conduct could not be found by a jury to be

“something approaching a total unconcern for the prisoner’s welfare in the face of

serious risks.” Rosario, 670 F.3d at 821 (quoting Collins, 462 F.3d at 762). Therefore,

summary judgment shall be granted in favor of Defendant Caldwell, as well.

III. Defendant Moldenhauer

Next, the Court reviews the undisputed evidence concerning Michael

Moldenhauer and his role in Anderson’s medical treatment. Moldenhauer has been

employed as a Nurse Practitioner by Wexford Health Sources, Inc. since January 15,

2013. (Doc. 63, Ex. D, ¶ 2). While at Menard, Moldenhauer saw Anderson

intermittently between March 4, 2018, and December 16, 2022. (Id., Ex. A, 97:11–20).

Moldenhauer’s first documented encounter with Anderson occurred on March

4, 2018; Anderson presented with a rash on his torso and reported that he had

previously been prescribed Benadryl. (Doc. 63, Ex. E, pp. 41, 148). Moldenhauer noted

itching and areas of darkened skin. (Id.). Anderson requested a long-term

prescription for Benadryl, which had previously been ordered by Dr. Siddiqui. (Id.).

In response, Moldenhauer prescribed a short three-day course of Benadryl 25 mg

twice daily and referred Anderson to Dr. Siddiqui for further evaluation regarding

the appropriateness of long-term use. (Id., Ex. D, ¶ 21). Moldenhauer explained that

under IDOC policy, Benadryl was generally not prescribed long-term for medical

conditions and that extended use was typically limited to psychiatric indications.

(Id.). He further stated that the short-term prescription was intended to provide

interim relief pending physician review. (Id.). Moldenhauer explained that once he

issued a referral, nursing staff were responsible for placing the patient on the

appropriate call line and that he did not control or create provider schedules. (Doc.

63, Ex. D, ¶ 22). Thus, although he initiated the referral, the actual scheduling was

handled by other personnel. (Id.).

On April 20, 2018, Anderson again presented to Moldenhauer with complaints

of dry skin related to his eczema. (Id., Ex. E, p. 45). During that visit, Moldenhauer

recorded that he observed no objective signs of dryness or eczema, described the

examination as normal, and noted that Anderson had already been referred to Dr.

Siddiqui. (Id.). Because he did not observe clinical signs of eczema at that time and a

referral was already pending, Moldenhauer did not issue an additional referral or

prescribe Benadryl. (Ex. D, ¶ 24).

On September 8, 2021, Anderson next presented to Moldenhauer with

complaints of a rash, worsening nighttime itching, and an expired Benadryl

prescription. (Doc. 63, Ex. E, pp. 397–98, 418). Moldenhauer recorded that he did not

observe a rash on examination. (Id.). Nevertheless, in response to Anderson’s

reported symptoms, he prescribed Benadryl 25 mg once daily for one month and

triamcinolone cream. (Id.). He also submitted a dermatology referral, noting

Anderson’s reported history of dermatologic evaluation and his request for renewed

medications. (Id., Ex. E, p. 367).

On December 3, 2021, Moldenhauer saw Anderson for renewal of his Benadryl

prescription. (Doc. 63, Ex. E, pp. 329, 423). He documented rough, dry skin on

Anderson’s lower body and noted that a dermatology appointment was expected in

January 2022. (Id.). He prescribed Benadryl 25 mg for one month and Triamcinolone.

(Id.). On March 1, 2022, nursing staff recorded verbal orders from Moldenhauer

renewing T-Gel shampoo, Kenalog ointment, and Benadryl 25 mg for six months. (Id.,

Ex. E, pp. 341, 428). Later, on December 16, 2022, after reviewing dermatology notes,

Moldenhauer prescribed Allegra, Zyrtec, Benadryl, and fluocinonide solution for one

year in accordance with dermatology recommendations. (Id., Ex. E, pp. 366, 448, 450).

These records reflect continued medication management of Anderson’s skin

complaints, including implementation of specialist recommendations.

The most contentious part of Moldenhauer’s care was his visit with Anderson

on March 4, 2018, wherein he prescribed Benadryl for only three days. (Id., Ex. E, pp.

41, 148). When asked why he was suing Moldenhauer, Anderson pointed specifically

to this interaction, asserting that he disagreed with the short duration of the

prescription because it would not remain effective in his system for a sufficient period.

(Id., Ex. A, 29:4–20).

The Court first considers that, as stated before, Eighth Amendment deliberate

indifference does not apply simply because a patient disagrees with a practitioner’s

course of treatment. Snipes, 95 F.3d at 591. Here, the short-term order of Benadryl

was prescribed after Moldenhauer noted that long-term Benadryl was prescribed by

Dr. Siddiqui. (Id., Ex. D, ¶ 21). Moldenhauer intended the short-term order to provide

temporary relief until Anderson could be reevaluated by Dr. Siddiqui. (Id.). He

further explained that IDOC policy generally restricted long-term Benadryl

prescriptions to psychiatric indications. (Id.). In his role as a Nurse Practitioner,

Moldenhauer followed that policy while simultaneously referring Anderson back to a

physician for further assessment.

However, Anderson did not see Dr. Siddiqui until May 14, nearly two and a

half months after Moldenhauer issued the referral. (Id., Ex. D, ¶ 22). Given the gap

between the three-day Benadryl order and the eventual long-term prescription by Dr.

Siddiqui, the Court considers whether this delay could constitute delayed medical

treatment, which may support a finding of deliberate indifference. See Berry, 604 F.3d

at 441 (“A significant delay in effective medical treatment also may support a claim

of deliberate indifference, especially where the result is prolonged and unnecessary

pain.”). However, even in cases of delayed treatment, a plaintiff must present

evidence that the defendant acted with the requisite bad intent in causing the delay.

Burton v. Downey, 805 F.3d 776, 785 (7th Cir. 2015). Here, Moldenhauer explained

the basis for his decision, including IDOC policy limitations and the need for

physician review, and the Court finds no evidence of bad intent. Moreover,

Moldenhauer demonstrated that he was not responsible for scheduling his own or

other providers’ call lines. (Doc. 63, Ex. D, ¶ 22). Considering the circumstances, the

Court concludes that Moldenhauer’s conduct does not amount to “something

approaching a total unconcern for the prisoner’s welfare in the face of serious risks,”

i.e., deliberate indifference. Rosario, 670 F.3d at 821 (quoting Collins, 462 F.3d at

762).

Viewed as a whole, the undisputed record shows that Moldenhauer evaluated

Anderson when he presented with complaints of itching and rash, documented his

clinical findings, prescribed medication, and referred him to other practitioners for

further assessment. Although Anderson disagreed with the dosing and duration of

certain prescriptions, the record reflects ongoing evaluation and treatment rather

than a refusal to address his skin condition. Construing the evidence in Anderson’s

favor, no reasonable jury could conclude that Nurse Practitioner Moldenhauer acted

with deliberate indifference and summary judgment shall be granted in

Moldenhauer’s favor.

IV. Defendants Lang and Crain

Finally, the Court addresses the undisputed evidence concerning Amy Lang

and Angela Crain and their respective roles in Anderson’s medical care. Because both

assert qualified immunity, their conduct is addressed together.

Lang works as a nurse at Menard. (Doc. 1, p. 2). Anderson contends that Lang

acted with deliberate indifference by refusing to renew his medications and by

preventing him from seeing a doctor. (Doc. 63, Ex. A, 117:1–120:2). However,

Anderson acknowledges that Lang lacked authority to prescribe medications and that

he ultimately was able to see a physician after submitting several grievances. (Id.,

119:22–120:3–11).

Ms. Crain serves as a healthcare unit administrator at Menard. (Id., 114:7–

10). Anderson argues that, because she is responsible for ensuring that medical staff

perform their duties, she is liable for his inability to obtain timely medication

renewals. (Id., 115:20–116:16). Crain responds that “it is the offender’s responsibility

to monitor the expiration date of his medication orders and submit a written request

to NSC for medication renewal,” and that on both occasions when Anderson’s

prescriptions expired, he failed to submit the required written request. (Doc. 56, Exs.

B, C).

Lang and Crain move for summary judgment on both deliberate indifference

and qualified immunity grounds. The Court addresses each argument in turn.

A. Deliberate Indifference

The Court first addresses Anderson’s claim that Lang refused to prescribe

Anderson his medication. Failure to prescribe medication when an individual does

not have the authority to prescribe medication has been consistently rejected as a

basis for a deliberate indifference claim. See, e.g., Patterson v. Wexford Health Care

Servs., No. 222CV00113JRSMJD, 2024 WL 1012961, at *11 (S.D. Ind. Mar. 8, 2024);

Harlow v. Hamlyn, No. 3:24-CV-956-HAB-SLC, 2024 WL 5007453, at *3 (N.D. Ind.

Dec. 6, 2024); Thompson v. Conant, No. 1:12-CV-1177-SEB-TAB, 2013 WL 4543042,

at *9 (S.D. Ind. Aug. 26, 2013), aff’d, 559 F. App’x 557 (7th Cir. 2014). Because Nurse

Lang’s ability to prescribe medication was lacking, Lang’s failure to prescribe

Anderson his medication does not equate to her ignoring Anderson’s complaints or

requests. Rather, she was simply unable to address them. Accordingly, Nurse Lang

did not act with deliberate indifference on this point.

Turning to Anderson’s argument that Lang denied his requests to see doctors

between 2017 and 2020, the Court concludes this is without merit. Anderson’s

medical records, discussed in detail throughout this Order, show that he saw doctors

regularly during this time. Without evidence of a specific instance where Lang’s

denial caused a delay in Anderson’s medical care, it is difficult to make a case for

deliberate indifference. See Gallo v. Sood, 651 Fed. App’x 529, 534 (7th Cir. 2016)

(holding that a nurse was not found to act with deliberate indifference where plaintiff

had not shown that her actions caused a month-long delay resulting in later

suffering). Anderson stated in his Deposition that he filed grievances in response to

Lang’s denial, but the grievances in question do not mention Lang by name. (See Doc.

1, Ex. A; id., Exs. B, C, E). In fact, in the grievance dated March 16, 2018, Anderson

stated that “the nurse” put him in to see a doctor and that he did see a doctor. (Id.,

Ex. B). Accordingly, the Court finds that Nurse Lang did not act with deliberate

indifference on this point.

Next, the Court addresses Anderson’s claim against Crain, namely, that she

was responsible for ensuring that medical staff performed their duties and could be

held liable when he failed to receive his medication. (Id., 115:20–116:16). To establish

deliberate indifference against a nonmedical prison official, a plaintiff must show

more than dissatisfaction with the outcome of medical care; they must show that the

administrator knew something was amiss with the acting physician’s treatment See

Rasho v. Elyea, 856 F.3d 469, 478–79. (7th Cir. 2017). The Seventh Circuit has held

that prison administrators are generally entitled to rely on the judgment of medical

professionals. Id. Where an inmate is under the care of qualified medical providers,

a nonmedical official may ordinarily assume that the inmate’s treatment is being

appropriately managed. See Johnson v. Doughty, 433 F.3d 1001, 1010–12 (7th Cir.

2006); Perkins v. Lawson, 312 F.3d 872, 875–76 (7th Cir. 2002). Thus, a nonmedical

official is entitled to summary judgment when she responds reasonably to an inmate’s

complaint, such as by confirming that the inmate has been evaluated or is scheduled

to receive medical attention, even if the inmate disagrees with the medical course

ultimately provided. See Johnson, 433 F.3d at 1010–12.

The undisputed record shows that Crain’s involvement consisted of responding

to grievances regarding expired Benadryl prescriptions. On March 3, 2020, she noted

that Anderson’s prior order had expired on November 21, 2019, and that a new order

was issued six days later. (Doc. 56, Ex. B). She further explained that inmates are

responsible for monitoring expiration dates and submitting written requests for

renewal. (Id.). On November 22, 2021, Crain responded to another grievance by

confirming that Anderson’s Benadryl prescription had expired on October 7, 2021,

that no renewal request had been submitted, and that he would be scheduled for

medication renewal. (Doc. 56, Ex. C).

Although Anderson contends that she failed to act promptly, the record reflects

that she reviewed the medication history and directed him through the established

renewal process when necessary. (Id., Ex. B). There is no evidence that Crain

prescribed, denied, or interfered with medical treatment, or that she disregarded a

known risk to Anderson’s health. Rather, her role was limited to administrative

oversight and grievance review, and she was entitled to rely on medical staff to

determine the appropriate course of treatment. Therefore, the Court finds that when

construing the evidence in favor of Anderson, the Court finds that Ms. Crain did not

act with deliberate indifference.

B. Qualified Immunity

Lang and Crain also argue that they are entitled to qualified immunity. (See

Doc. 56, pp. 11–12). While the Court need not assess Defendants Lang and Crain’s

qualified immunity argument due to the fact that Anderson’s Eighth Amendment

claims do not survive Lang and Crain’s Motion for Summary Judgment, the Court

will briefly discuss the applicability of qualified immunity to the instant facts.

Defendants argue that they are entitled to qualified immunity because

“[g]overnment officials performing discretionary functions generally are shielded

from liability for civil damages if their conduct does not violate clearly established

statutory or constitutional rights of which a reasonable person would have known.”

(Doc. 56, p. 11 (citing Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982)). They argue

that “to determine whether an official is entitled to qualified immunity, a two-part

inquiry is required: (1) whether a constitutional right would have been violated on

the facts alleged, and (2) whether the right alleged to have been violated was clearly

established.” (Id. (citing Saucier v. Katz, 533 U.S. 194, 200 (2001))). Defendants argue

that a constitutional right was not violated because Defendants were not deliberately

indifferent toward Anderson’s medical needs and that no clearly established right

was violated because neither Defendant observed Anderson’s rash nor did he suffer

any serious injury from intermittent medical delay. (Id., pp. 11–12).

Regarding Anderson’s Eighth Amendment claim, the Seventh Circuit has

established that “[w]hen considering deliberate-indifference claims challenging the

medical judgment of prison healthcare personnel, qualified-immunity analysis

requires us to frame the legal question with reasonable specificity.” Campbell v.

Kallas, 936 F.3d 536, 546 (7th Cir. 2019). In Campbell, the Seventh Circuit

determined that “[t]he proper inquiry is whether then-existing caselaw clearly

established a constitutional right to gender-dysphoria treatment beyond hormone

therapy” not “that ‘denying effective treatment’ for Campbell’s medical condition

violates the Eighth Amendment” because the latter “formulation—which is basically

a highly conceptualized version of the deliberate-indifference standard—is far too

general.” Id. at 546. Additionally, “‘[f]or purposes of qualified immunity, [the Eighth-

Amendment] duty’ to treat prisoners’ serious medical conditions ‘need not be litigated

and then established disease by disease or injury by injury.’” Id. at 548 (quoting Est.

of Clark, 865 F.3d at 553). Moreover, “[w]hen prison officials utterly fail to provide

care for a serious medical condition, the constitutional violation is obvious and

qualified immunity offers little protection.” Id. (citing Orlowski v. Milwaukee County,

872 F.3d 417, 422 (7th Cir. 2017)).

Here, Defendants’ argument succeeds because prison officials did not persist

in ineffective treatments. See id. at 547 (quoting Greeno v. Daley, 414 F.3d 645, 655

(7th Cir. 2005) (citing Petties, 836 F.3d at 729–30). It has clearly been established

that the Defendants treated Anderson’s eczema to the extent necessary in their

respective roles. Further, like in Campbell, there is no Circuit precedent indicating

that the chosen course of care for Anderson’s eczema violated a constitutional right,

meaning the Defendants were not on notice of a constitutional violation and would be

entitled to qualified immunity if the Court reached that question.

CONCLUSION

For the reasons set forth above, Defendants’ Mohammed Siddiqui, Reynal

Caldwell, and Michael Moldenhauer’s Motion for Summary Judgment (Doc. 62) and

Defendants’ Amy Lang and Angela Crain’s Motion for Summary Judgment (Doc. 56)

are both GRANTED. This case is DISMISSED with prejudice. The Clerk of Court

is DIRECTED to close this case on the Court’s docket.

IT IS SO ORDERED.

DATED: March 13, 2026

/s/ Stephen P. McGlynn_

STEPHEN P. McGLYNN

U.S. District Judge