LAW.coLAW.co

Samuel Albright BROWN, Jr., Plaintiff-Appellant, v. NORTH CAROLINA DEPARTMENT OF CORRECTIONS; FNU Winkler, Officer; FNU Simms, Officer; FNU Teague, Officer, Defendants-Appellees

United States Court of Appeals for the Fourth Circuit2010-01-11No. No. 08-8501
612 F.3d 720

Summary

Holding. The court vacated the district court's dismissal and remanded the case for further proceedings, holding that the inmate's complaint alleged sufficient facts to state a plausible claim of deliberate indifference against the three correctional officers under the Eighth Amendment.

An inmate at a North Carolina correctional facility filed a federal civil rights lawsuit alleging that three correctional officers violated his Eighth Amendment rights by displaying deliberate indifference to his safety. The inmate alleged that one officer sent him into a housing area despite knowing another inmate harbored a grudge against him, that a second officer witnessed the subsequent assault but failed to intervene, and that a third officer was present during the attack without stopping it. The inmate suffered serious physical injuries requiring surgical intervention and ongoing medical care as a result of the assault.

The district court had dismissed the inmate's complaint for failure to state a valid legal claim. The appellate court disagreed, finding that the inmate's allegations were sufficient to survive an initial screening review. The court determined that the complaint adequately described how each officer either created a dangerous situation or failed to respond to an obvious threat, satisfying the legal requirements for an Eighth Amendment claim based on deliberate indifference to inmate safety.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether prison officials have a duty to protect inmates from violence by other inmates
  • Whether allegations of serious physical injury satisfy the 'sufficiently serious deprivation' element of an Eighth Amendment claim
  • Whether a prison official's knowledge of danger and failure to prevent harm constitutes 'deliberate indifference'
  • Whether allegations that an officer knowingly placed an inmate in danger state a valid claim

Procedural posture

The inmate appealed the district court's dismissal of his § 1983 civil rights complaint under 28 U.S.C. § 1915A, which requires screening of prisoner complaints.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

OPINION

LEGG, District Judge:

Samuel Albright Brown, an inmate incarcerated at the Alexander Correctional Institute (“ACI”) in Taylorsville, North Carolina, filed the instant suit under 42 U.S.C. § 1983, alleging that Defendants, Correctional Officers Winkler, Teague, and Simms, and the North Carolina Department of Corrections, violated his rights under the Eighth Amendment of the United States Constitution. Specifically, Brown alleges that Defendants were deliberately indifferent to the serious harm he suffered at the hands of a fellow inmate. The district court, after reviewing the complaint pursuant to 28 U.S.C. § 1915A, dismissed the complaint for failure to state a claim upon which relief may be granted. Because we disagree with the district court’s finding that Brown’s complaint fails to state a claim upon which relief may be granted, we vacate its dismissal of the case and remand the matter for further proceedings.

I.

Brown’s complaint alleges the following facts. On May 9, 2008, an ACI staff member instructed him to enter the “Housing Block” to retrieve a number of cleaning supplies. The staff member gave the instruction despite having knowledge that another inmate in the Housing Block harbored a grudge against Brown. While gathering the cleaning supplies, Brown was assaulted and brutally beaten by that inmate. As a result of that assault, a steel plate was inserted into Brown’s jaw and he received “ongoing” medical care for “permanent” injuries.

Brown’s complaint further alleges that Officer Simms was in “the Block” when the assault occurred, that Officer Teague observed the assault, and that the “staff officers in question were [negligent and placed [Brown] in a dangerous and vulnerable position.”

In an administrative grievance form attached to his complaint, Brown specified that Officer Winkler was the staff member who was aware of the other inmate’s grudge against Brown but nonetheless sent him to pick up cleaning supplies. The administrative grievance form also alleges that Officer Teague admitted to Brown that he witnessed the assault but chose not to intervene.

The district court dismissed the case pursuant to § 1915A, finding that Brown’s complaint failed to state a claim upon which relief may be granted. Brown now appeals the dismissal of his claims against Officers Winkler, Teague, and Simms. He does not appeal, however, the dismissal of his claim against the North Carolina Department of Corrections.

II.

Under § 1915A, district courts are required to review “any complaint in a civil action in which a prisoner seeks redress from a governmental entity.” 28 U.S.C. § 1915A(a). In doing so, a court must either “identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint ... fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915A(b)(l).

A complaint should be dismissed “if it does not allege ‘enough facts to state a claim to relief that is plausible on its face.’ ” Giarratano v. Johnson, 521 F.3d 298, 302 (4th Cir.2008) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)). In evaluating a complaint, this Court “will construe the factual allegations ‘in the light most favorable to the plaintiff.’ ” Schatz v. Rosenberg, 943 F.2d 485, 489 (4th Cir.1991) (quoting Battlefield Builders, Inc. v. Swango, 743 F.2d 1060, 1062 (4th Cir.1984)). Here, “[l]iberal construction of the pleading is particularly appropriate” because it “is a pro se complaint raising civil rights issues.” Loe v. Armistead, 582 F.2d 1291, 1295 (4th Cir.1978) (citing Haines v. Kerner, 404 U.S. 519, 521, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972)). We review de novo dismissals for failure to state a claim. Schatz, 943 F.2d at 489.

III.

The Eighth Amendment imposes a duty on prison officials “to protect pxisoners from violence at the hands of other prisoners.” Farmer v. Brennan, 511 U.S. 825, 833, 114 S.Ct. 1970, 128 L.Ed.2d 811 (1994). Not every injury suffered by a prisoner at the hands of another establishes liability against a prison official, however. To make a valid claim under the Eighth Amendment, a prisoner must satisfy two elements. First, “the deprivation alleged must be sufficiently serious.” Odom v. S.C. Dep’t of Corr., 349 F.3d 765, 770 (4th Cir.2003) (internal quotation marks and citation omitted). “To demonstrate such an extreme deprivation, a prisoner must allege a serious or significant physical or emotional injury resulting from the challenged conditions.” Id. In this case, it is uncontested that Brown suffered significant physical injuries as a result of the other inmate’s attack.

Second, a prisoner must demonstrate that the prison official had a “sufficiently culpable state of mind.” Id. (quoting Wilson v. Seiter, 501 U.S. 294, 298, 111 S.Ct. 2321, 115 L.Ed.2d 271 (1991)). When an inmate makes a challenge under the Eighth Amendment, “the requisite state of mind is one of deliberate indifference to inmate health or safety.” Id. (internal quotation marks and citation omitted). A prison official demonstrates deliberate indifference if he “knows of and disregards an excessive risk to inmate health or safety.” Id. In other words, “the test is whether the guards know the plaintiff inmate faces a serious danger to his safety and they could avert the danger easily yet they fail to do so.” Case v. Ahitow, 301 F.3d 605, 607 (7th Cir.2002).

Applying that two-pronged test to the instant facts, we hold that the district court erred in dismissing Brown’s claims against Officers Winkler, Teague, and Simms.

A.

The State of North Carolina, representing each of the Defendants, concedes error with respect to the claims against Officers Winkler and Teague. The state acknowledges that the complaint sufficiently alleges that Officer Teague observed the altercation and failed to respond. The state also acknowledges that Brown’s administrative grievance form states that Officer Winkler was aware of the other inmate’s grudge but still sent Brown into the Housing Block to pick up supplies. We agree that those allegations sufficiently state a claim upon which relief may be granted. As a result, the district court should not have dismissed Brown’s claims against Officers Winkler and Teague.

B.

The State of North Carolina does not concede error with respect to the claim against Officer Simms. The state contends that no reasonable person could infer from the complaint that Officer Simms knew of the assault in time to intervene, yet deliberately and indifferently failed to do so.

We disagree with that reading of the record. Brown’s complaint alleges that Officer Simms was in “the Block” when the assault occurred. A reasonable person could infer from that statement that Officer Simms was aware of the attack, and that his failure to intervene represented deliberate indifference to a serious risk of harm.

Similarly, Brown’s complaint states that “staff members” were aware of the other inmate’s grudge, that the staff members knew there were prior problems between that inmate and Brown, and that they placed Brown “in a [djangerous and vulnerable position.” Because there were only three ACI correction officers designated in the complaint, it is reasonable to assume that Brown was naming Officer Simms when he described the staff members who were deliberately indifferent to the serious harm posed by his fellow inmate. Accordingly, the district court should not have dismissed Brown’s claim against Officer Simms.

IV.

Because Brown’s complaint alleges facts sufficient to state a plausible claim, we vacate the district court’s dismissal under § 1915A and remand the matter for further proceedings.

VACATED AND REMANDED