From the Courts
Author: Ken Kozlowski.
Source: Volume 27, Number 01, Winter 2026 , pp.7-9(3)

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Abstract:
Our regular review of appellate rulings includes three cases: Parker v. Holmen (7th Cir. 2025), affirming summary judgment for prison nurses where a Wisconsin inmate who mistakenly received another prisoner’s medication failed to show the nurses knowingly disregarded a substantial risk of harm and therefore could not establish deliberate indifference under the Eighth Amendment; Coones v. Cogburn (5th Cir. 2025), holding that the surviving parent of a Texas inmate who died during extreme heat plausibly alleged Eighth Amendment violations against supervisory officials and medical staff for failing to address dangerous temperatures and evident medical distress, allowing those claims to proceed while affirming dismissal of ADA and malpractice claims; and Rosario v. Wetzel (3d Cir. 2025), affirming summary judgment for prison officials where a mentally ill prisoner’s prolonged restrictive housing and treatment were justified by legitimate security concerns, periodically reviewed, and accompanied by ongoing psychiatric care, defeating Eighth Amendment, due process, and ADA claims.Keywords: Deliberate Indifference; Prison Medical Care; Extreme Heat; Solitary Confinement; Qualified Immunity; Prison Litigation Reform Act
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