COX v. QUINN, NO. 15-6943
Decided: July 6, 2016
The Fourth Circuit affirmed the district court’s ruling.
Appellee Dewayne Cox was severely beaten by a fellow inmate and alleges that appellant police officers were deliberately indifferent to a substantial risk to the appellee’s safety. Cox argued that the correctional officers’ lack of appropriate response to his repeated complaints was in direct violation of 42 U.S.C. § 1983 and the Eighth Amendment. The district court denied summary judgment to the correctional officers, finding that they were not entitled to qualified immunity on Cox’s claims. At issue in this appeal is whether the district court correctly denied qualified immunity at summary judgment, specifically if the correctional officers’ conduct violated a constitutional right and if an objectively reasonable officer could have believed that his actions were lawful “in light of clearly established law.”
The Eighth Amendment requires prison officials to “take reasonable measures to guarantee the safety of the inmates.” The district court analyzed previous case law from the Fourth Circuit Court and the Supreme Court of the United States to anticipate how it would rule. Consequently, the Fourth Circuit understood that a prison official will not be liable for failing to protect a prisoner from inmate violence unless two requirements are met: the deprivation alleged must be, objectively, sufficiently serious and the defendant prison official must have had a “sufficiently culpable state of mind.”
The court found that the injuries sustained by Cox were not in dispute and thus the first prong, requiring that the prisoner allege a serious or significant physical or emotional injury resulting from the challenged conditions, was not in question. The second prong, requiring a “sufficiently culpable state of mind”, was central to this appeal. The court determined that the state of mind required in prison-conditions cases is “‘deliberate indifference’ to inmate health or safety.” The prison official must subjectively recognize that substantial risk and also subjectively be aware that “his actions were ‘inappropriate in light of that risk.’” Most notably, the Eighth Amendment requires not just action, but reasonable action.
Further, “even if a correctional officer has violated a prisoner’s constitutional right he may be shielded from liability by qualified immunity if an objectively reasonable officer could have believed that his actions were lawful in light of clearly established law.” Here, the court determined that an objectively reasonable officer would have known the actions taken by the officers in this case were unreasonable and thus violated Cox’s constitutional rights.
Because the Fourth Circuit determined that in light of the facts an objectively reasonable corrections officer, either certified or uncertified, would have known that the actions taken by the appellants were unreasonable and were counter to clearly established law, the Fourth Circuit held that the correctional officers were not entitled to qualified immunity.
Accordingly, the Court affirmed the district court’s ruling.