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Wilford Allen Knight v. Gary Gill Stephen T. Smith and John Wigginton

Citations: 999 F.2d 1020; 1993 U.S. App. LEXIS 19393; 1993 WL 281642Docket: 92-6068

Court: Court of Appeals for the Sixth Circuit; July 29, 1993; Federal Appellate Court

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Defendants Gary Gill, Stephen T. Smith, and John Wigginton appeal the denial of their summary judgment motion in a 42 U.S.C. § 1983 action brought by inmate Wilford Allen Knight following an assault by his cellmate on December 9, 1989. Knight sustained injuries requiring medical attention after being attacked with boiling water and fists. He filed the lawsuit on July 5, 1990, claiming violations including Eighth Amendment rights, gross negligence, failure to protect, failure to follow policy, and infliction of emotional distress.

The defendants argued for summary judgment based on qualified immunity, asserting that their actions did not violate any clearly established rights. However, Knight provided evidence that prison officials were aware of his cellmate's violent history and that Gill ignored Knight's requests for a cell transfer, despite a history of threats. The district court found sufficient factual disputes regarding the defendants' knowledge and potential misconduct to deny the motion for summary judgment, allowing the case to proceed to trial. The defendants subsequently filed a timely appeal on August 14, 1992, regarding the denial based on qualified immunity, which is considered an immediately appealable collateral order.

Review of a district court's qualified immunity decision is conducted de novo. To establish a claim under 42 U.S.C. § 1983, a plaintiff must identify a constitutional right and demonstrate its deprivation by someone acting under state law. Summary judgment is warranted when, viewing the evidence favorably to the non-moving party, no genuine material facts remain for trial, allowing the moving party to prevail as a matter of law.

Knight's Eighth Amendment claim against Defendant Gill hinges on whether Gill exhibited deliberate indifference to Knight’s safety by denying his transfer to another cell and only offering isolation. Additionally, Knight attributes his claims against Defendants Smith and Wigginton to their failure in properly training and supervising prison personnel, thereby violating his Eighth Amendment rights.

The assessment of deliberate indifference requires determining if the defendants' actions posed a risk of injury to Knight. The standard, articulated in Estelle v. Gamble, mandates that correctional officials must take reasonable measures to protect inmates from harm by other inmates. The Supreme Court clarifies that deliberate indifference does not necessitate a specific intent to inflict pain but is characterized by obduracy and wantonness, rather than mere negligence.

The district court's rejection of the defendants' qualified immunity claim is contested, with a finding that Knight did not adequately prove the defendants acted with the requisite obduracy and wantonness. Despite Knight's requests for a cell transfer, he merely cited "incompatibility problems" and declined protective measures pending a reassignment hearing. While he described the conditions in isolation as harsh, his stay would have been temporary, ensuring separation from Loran.

Defendants did not possess 'actual knowledge' of an imminent threat to Knight's safety, as he failed to report a prior scuffle before the scalding water incident. The district court's claim that Defendant Gill was aware of a danger and neglected to act is unsupported by evidence. In reviewing the facts favorably for Marsh, it is clear that Amis was only aware of Leonard's previous fights and Marsh's request to change rooms, which does not constitute actual knowledge of a specific risk to Marsh. Furthermore, Knight did not establish that defendants Smith and Wigginton had inadequate training or supervision. Their argument, based on the correctional complex's low assault rate, did not substantiate a duty to monitor violent inmates more closely. Thus, the court finds no evidence of deliberate indifference by the defendants and, consequently, vacates the district court's order, granting summary judgment in favor of the defendants.