Rick Knight filed a complaint for compensatory and punitive damages against two officers and a doctor with the Illinois Department of Corrections in U.S. District Court Feb. 16, claiming the defendants each demonstrated deliberate indifference to his medical needs.

He claims their actions resulted in him being subjected to cruel and unusual punishment in violation of the protections guaranteed by the eighth and fourteenth amendments of the U.S. Constitution.

Knight claims Vipin Shah, M.D. was a doctor at Vandalia Correction Center in charge of making sure inmates received timely and adequate medical treatment.

According to the complaint filed by attorney Donald Smith of Alton, Knight had arthroscopic surgery in July 2004, to repair a torn rotator cuff in his right shoulder. On Dec. 3, 2004, he was sentenced to four years in prison. Records are not available regarding the crime he committed.

Knight claims after arriving at the prison in Vandalia, he informed Shah that he had a reconstructed right shoulder and was given a pass to sleep in the bottom bunk, but claims Shah failed to place restrictions on the types of labor that he could perform.

He claims that on Feb. 16, 2005, he was ordered by two officers on a work crew to cut down trees, remove logs, and remove brush along the roadside in Fayete County.

Knight claims he informed the two officers of his shoulder condition, but they ordered him to throw the logs out of the ditch instead of rolling them up like he was previously doing.

According to the complaint, Knight felt a tearing sensation in his right shoulder and immediately experienced extreme pain. He claims he was told to use one arm to finish the job and was not allowed to seek medical aid for at least two hours after the injury.

He claims once back at the prison, Shah looked at the shoulder and told him that it would heal in a week or so. Knight claims Shah refused to order an x-ray, MRI, CT Scan, or pain medication.

He claims he was finally taken to a shoulder specialist in May 2005, who confirmed he had re-injured his shoulder.

Knight claims that on June 27, 2005, he had surgery performed by an Effingham doctor and on return to the prison he gave the form and the prescription form to Shah.

He claims that after hearing nothing about the surgery or medication, he asked Shah who informed him that he lost both forms.

Knight claims he suffered severe pain, suffering, discomfort, disfigurement, mental anguish and loss of a normal life.

"Each of the defendants' conduct was deliberately callous, done with malice and done in reckless disregard of plaintiff's right to be free from cruel and unusual punishment," the complaint states.

Knight is seeking damages in excess of $175,000.

The case has been assigned to District Judge David Herndon.

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