Bobby Brown v. Gregg Scott, 17-1547

Bobby Brown, a civil detainee at Rushville Treatment and Detention Facility, was sprayed with boiling coffee by another detainee and fought back.
Brown was placed two days in temporary special management, then a disciplinary committee convicted him of fighting without reviewing video evidence Brown says shows self-defense.
He received 30 days of "close status" (earlier curfew, reduced visitation, restricted access to yard/library/exercise) and 90 days of a transport cuff-box.
After close status ended, staff returned Brown to the same housing unit as his attacker; Brown complained and says he feared further attack every day and night.
The district court dismissed Brown’s complaint under 28 U.S.C. § 1915A for failure to state a claim, denied his due-process and housing claims, and rejected his late amended complaint.

Issue	Brown's Argument	Scott et al.'s Argument	Held
Whether disciplinary sanctions (close status and transport cuff-box) deprived Brown of a protected liberty interest under the Due Process Clause	Brown: close status and transport restraints were punitive and required due-process protections including consideration of exculpatory video	Defs: the sanctions were not an "atypical and significant" hardship; no protected liberty interest was implicated	Court: No liberty interest was deprived; prior precedent holds close status and similar restraints do not trigger due process (dismissed)
Whether housing Brown in same unit as his attacker violated detainee's right to safety (failure-to-protect)	Brown: being returned to same unit created ongoing, daily fear for his safety and amounted to a constitutional risk	Defs: mere fear is insufficient; no new threats were made and defendants lacked knowledge of any renewed threat	Court: Dismissed—subjective fear alone does not state a constitutional claim; no allegation defendants knew of a renewed threat
Whether the appeal/filing defects deprived the court of jurisdiction	Brown: filed a post-judgment "Motion to Object" within 30 days and later filed a notice of appeal	Defs: (not participating)	Court: Treated the timely motion as a functional notice of appeal and found jurisdiction secure

Turley v. Rednour, 729 F.3d 645 (7th Cir. 2013) (pleadings accepted as true at screening)
Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (protected liberty interest analysis for prison disciplinary measures)
Miller v. Dobier, 634 F.3d 412 (7th Cir. 2011) (close status and transport restraints do not create a liberty deprivation)
Klebanowski v. Sheahan, 540 F.3d 633 (7th Cir. 2008) (subjective fear of past attacker insufficient without a known or imminent threat)
Babcock v. White, 102 F.3d 267 (7th Cir. 1996) (distinguishes fear from a "reasonably preventable assault itself" for constitutional claims)
Collignon v. Milwaukee Cty., 163 F.3d 982 (7th Cir. 1998) (state must provide minimum level of safety for detainees)