RAYNOR v. PUGH, No. 14-7746

Decided: March 17, 2016

The Fourth Circuit vacated the district court’s ruling and remanded it for further proceedings.

James Raynor, an inmate at Sussex II State Prison, suffers medical ailments, including seizures, blackouts, blood issues, heart issues, and breathing issues. In November 2012, Raynor, who was housed with inmate Mullins asked prison officials to move him to a different cell with a “caretaker” inmate who had volunteered to assist Raynor with his conditions. Raynor renewed his request on January 10, 2013, with G. Pugh, the Prison Housing Manager. Pugh informed Mullins that he would be relocated to a different cell instead of moving Raynor. Raynor alleged that Mullins threatened him in front of Pugh and that Mullins claimed he “would physically assault [Raynor].” Raynor alleges that Pugh acted indifferently toward Mullins’ threats and that Pugh witnessed Mullins assault and injure Raynor without doing anything to stop it. Raynor suffered significant injury from the assault and became confined in a wheelchair as a result. Raynor filed a 42 U.S.C. § 1983 claim against Pugh, stating that Pugh’s indifference to the prison assault was “cruel and unusual” under the 8th amendment. The district court granted Pugh’s motion for summary judgment while acknowledging the parties “dispute[d] both defendant’s motivation in not breaking up the fight between plaintiff and Mullins” and whether Raynor “suffered a severe injury to his spinal cord.” However, the court concluded that these disputes were not “genuine” due to an asserted lack of evidentiary support for Raynor’s claim.

The 4th Circuit looked at a two-part test that included an objective and subjective inquiry in order for a plaintiff prisoner to attach liability to a prison guard. The objective inquiry requires the inmate to establish a serious deprivation of his rights in the form of a serious or significant physical or emotional injury. The subjective inquiry requires the inmate to show the prison official had a sufficiently culpable state of mind, which consists of deliberate indifference to inmate health or safety. This second factor is based on if the officer had a reasonable opportunity to act and simply refused to do so. The court applied the two-prong test to the present case. The court found there was evidence from Raynor that showed the seriousness of Raynor’s injuries from the assault and Pugh’s contrary evidence about the seriousness of the injury shows a genuine dispute about this prong to preclude summary judgment. Raynor’s evidence in his verified complaint and other as does Pugh actually witnessing the assault in person. Pugh’s version of not being a witness to the assault brings this second prong into dispute and precludes Pugh’s motion for summary judgment. The district court erred in granting summary judgment.

Judge Kennan concurred in part and concurred in the judgment because in her view Raynor’s complex medical history and his reliance on lay causation opinion, he has not yet raised a genuine dispute regarding the cause of his alleged injury. Because this defect may be remedied during the course of future discovery in this case, Raynor is entitled to have the lower court’s summary judgment award vacated.

Full Opinion

Ryan Jones

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