Anderson v. Morrison, 835 F.3d 681

Plaintiff Leroy Anderson, an Illinois prisoner, was handcuffed behind his back and ordered to descend a flight of 13 stairs at Stateville during a cell shakedown.
The stairs were allegedly slick with milk and cluttered with several days’ worth of food and garbage.
Anderson requested assistance; the guards refused and would not let him steady himself.
He slipped, fell, was knocked unconscious, and claims continuing and permanent injuries.
Anderson sued two guards under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference to a substantial risk of serious harm.
The district court dismissed under Fed. R. Civ. P. 12(b)(6), finding slippery stairs alone did not present a sufficiently serious risk; the Seventh Circuit vacated and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stair conditions posed a "substantial risk of serious harm" under the Eighth Amendment	Stairs were slippery with milk, clogged with garbage, and created an obstacle course that presented a significant risk of severe injury	Slippery surfaces (like showers) do not, without more, constitute a constitutional violation	Held: Yes — the combination of slick, debris-strewn stairs increased the risk beyond ordinary wet surfaces and could be substantial
Whether guards were deliberately indifferent by handcuffing Anderson behind his back and refusing help	Forcing an unaided, cuffed inmate to descend dangerous stairs despite his request was deliberate indifference to an obvious risk	Faulty analogy to cases involving showers or unavoidable wet floors; argues risk here is not constitutionally cognizable	Held: Allegations sufficiently plead deliberate indifference because guards knew inmate could not steady himself and refused assistance
Whether prior cases foreclose relief (e.g., Pyles v. Fahim)	Distinguishes Pyles because Anderson alleges "more": debris, 13 stairs, handcuffed behind back, refusal to assist	Defendants rely on Pyles and other circuits holding slippery shower floors or shackling in showers insufficient	Held: Distinguishable — Pyles and shower cases involve unavoidable wetness and lesser risk; facts here may state an Eighth Amendment claim

Farmer v. Brennan, 511 U.S. 825 (prison officials must not be deliberately indifferent to substantial risks of serious harm)
Helling v. McKinney, 509 U.S. 25 (Eighth Amendment covers future health risks from prison conditions)
Pyles v. Fahim, 771 F.3d 403 (7th Cir.) (slippery surfaces and shower floors, without more, do not establish Eighth Amendment violation)
Powers v. Snyder, 484 F.3d 929 (conditions that recklessly endanger a prisoner can state an Eighth Amendment claim)
Board v. Farnham, 394 F.3d 469 (known or obvious dangers to inmates can give rise to constitutional claims)
LeMaire v. Maass, 12 F.3d 1444 (9th Cir.) (shackling while using shower not per se unconstitutional)
Reynolds v. Powell, 370 F.3d 1028 (10th Cir.) (failing to drain shower area used by an inmate on crutches did not state a constitutional claim)
Carroll v. DeTella, 255 F.3d 470 (prisons not required to provide maximally safe environment)
Withers v. Wexford Health Sources, Inc., 710 F.3d 688 (obvious, easily preventable hazards that pose serious risk must be addressed)
Smith v. Peters, 631 F.3d 418 (similar principle on preventable risks in custody)
Gates v. Cook, 376 F.3d 323 (prison officials must address known, substantial risks)
Perez v. Fenoglio, 792 F.3d 768 (district courts should consider recruiting counsel in complex Eighth Amendment claims)