Alfred Days v. Warden Scott Crickmar, 701 F. App'x 883

Alfred Days, an inmate at Hays State Prison, reported gang threats after refusing to bring contraband into the prison while on outside work. He sought protective custody and wrote letters to Warden Crickmar and Deputy Warden Hammock.
Prison officials opened an investigation and placed Days in Y dorm, which the parties agree was the safest dorm; Days admitted he felt safe there.
Days was later assigned to kitchen duty and again admitted he felt safe working there. He did not request protective custody after these changes.
Weeks after the investigation ended, while working in the kitchen bathroom, Days was beaten and sexually assaulted by gang members.
Days sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference by Crickmar and Hammock for failing to place him in protective custody; the district court granted summary judgment for defendants on qualified immunity grounds.
The Eleventh Circuit affirmed, finding Days failed to show defendants acted unreasonably given the investigation, relocation to Y dorm, and kitchen assignment — and Days’ own admissions that he felt safe and ceased requesting protective custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants were deliberately indifferent to a substantial risk of harm	Days: defendants knew of gang threats and failed to place him in protective custody, leading to attack	Defendants: they investigated, relocated Days to a safe dorm and kitchen work; Days felt safe and stopped requesting protection	Held: No. Days failed to show defendants disregarded a known risk or acted unreasonably
Whether a genuine dispute of material fact exists about defendants’ reasonableness	Days: factual disputes (e.g., access to Y dorm; continued requests for custody) preclude summary judgment	Defendants: record and Days’s admissions show safety measures and cessation of custody requests; no contrary evidence	Held: No genuine material factual dispute; admissions and record support defendants’ actions
Causal link between defendants’ conduct and harm	Days: defendants’ failure to place him in protective custody caused his assault	Defendants: relocation and work assignment negated ongoing risk; no evidence defendants knew risk persisted	Held: Plaintiff did not establish the required causal connection because officials’ actions were reasonable
Need to reach qualified immunity analysis	Days: defendants not entitled to immunity because constitutional violation alleged	Defendants: asserted qualified immunity	Held: Court did not address qualified immunity because Days failed to state a § 1983 claim on the merits

Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (Eighth Amendment requires prison officials not be deliberately indifferent to substantial risks of serious harm)
Bowen v. Warden Baldwin State Prison, 826 F.3d 1312 (11th Cir. 2016) (three-prong deliberate indifference test for inmates)
Melton v. Abston, 841 F.3d 1207 (11th Cir. 2016) (standard of review for summary judgment)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (definition of a genuine dispute of material fact at summary judgment)
Rodriguez v. Sec’y for Dept. of Corr., 508 F.3d 611 (11th Cir. 2007) (prison officials’ duty to protect inmates)
Reese v. Herbert, 527 F.3d 1253 (11th Cir. 2008) (district courts must verify record citations supporting summary-judgment facts)
Feliciano v. City of Miami Beach, 707 F.3d 1244 (11th Cir. 2013) (appellate affirmance possible on any record-supported basis)
Shuford v. Fidelity Nat’l Prop. & Cas. Ins. Co., 508 F.3d 1337 (11th Cir. 2007) (viewing facts and inferences in favor of non-moving party)