Decided: July 3, 2014
The Fourth Circuit held that the district court erred in denying the defendants’, employees at a federal detention center, motion for summary judgment based on qualified immunity.
After he was assaulted by another inmate in the Butner, North Carolina Federal Correctional Institute, Plaintiff, David Danser, alleged that Theron Boyd, a correctional officer, Lieutenant Bobby Roy, Boyd’s immediate supervisor, and Patricia Stansberry, the prison warden, violated Danser’s Eighth Amendment right to be free from cruel and unusual punishment. Specifically, Danser alleged that the defendants showed deliberate indifference to his safety. Defendant Boyd’s job duties included, inter alia, grouping inmates in the recreation cages for outdoor time and supervising the recreation area. Boyd assigned Danser, who was serving a sentence for sexual abuse and exploitation of a minor, and possession of child pornography, and three other inmates, including a member of a violent prison gang, to the same recreation cage. In violation of his duties, Boyd left the recreation area for several minutes. While Boyd was gone, the gang member assaulted Danser, and during the assault commented about Danser’s sexual abuse of children. Danser suffered “a ruptured spleen, a punctured lung, some broken ribs, and numerous bruises and abrasions.” The defendants filed a motion for summary judgment on the basis of qualified immunity, and the district court denied the motion.
In reviewing the district court’s decision to reject the defendants’ qualified immunity claim, the Court applied the two-step Saucier test. The Saucier test first requires that the reviewing court “decide whether the undisputed facts show that the government official’s actions violated the plaintiff’s constitutional rights.” Saucier v. Katz, 533 U.S. 194, 201 (2001). If the first step is satisfied, then the court “must determine whether the right at issue was ‘clearly established’ at the time of the events in question.” Id. To prove the deprivation of a constitutional right a prisoner must show (1) a serious deprivation in the form of a “serious or significant physical or emotional injury,” Brown v. N.C. Dep’t of Corr., 612 F.3d 720, 723 (4th Cir. 2010), and (2) that the prison official allegedly responsible for the deprivation had a “sufficiently culpable state of mind.” Farmer v. Brennan, 511 U.S. 825, 834 (1994). Here Danser suffered serious physical injuries, thus the Court found the first element was satisfied. Specific to the claim against Boyd, the Court reasoned that Boyd may have been negligent when he left the inmates unsupervised, but that Danser failed to provide any evidence to suggest that Boyd acted out of deliberate indifference. With respect to the claims against Stansberry and Roy, the Court concluded that the district court’s conclusions were erroneous for two reasons. First, government officials cannot be held liable under a theory of respondeat superior. Second, the record revealed no evidence that the prison had a policy or practice that failed to provide adequate protection for sex offenders. Because Danser failed to prove the first step of the Saucier test, the Court concluded that the district court erred in denying the defendants’ summary judgment motion on the basis of qualified immunity without reaching the second step of the Saucier test.
Amanda K. Reasoner