Boyd v. Helniski, 5:19-ct-03020-FL

Plaintiff Fred Lamar Boyd, a pretrial detainee at Wake County Detention Center, sued correctional officers Helniski and Smith under 42 U.S.C. § 1983, alleging they placed a white powdery substance in his food on multiple dates, causing chest pain and high blood pressure.
Boyd testified he observed the powder being placed but did not eat the tampered meals; he also speculated other meals he ate might have been tampered with.
Defendants moved for summary judgment after discovery; Boyd was notified under Roseboro but did not file a response.
Medical records and affidavits presented by defendants show no identification of the powder or medical causation linking it to Boyd’s chest pain; medical staff could not identify a cause for the chest pain.
The district court granted summary judgment for defendants on the federal claims for lack of evidence on the objective element of an Eighth/Fourteenth Amendment conditions claim, and dismissed any state-law claims without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the objective element of a conditions-of-confinement claim is met (serious physical or emotional injury or substantial risk)	Boyd contends powder in food caused chest pain and high blood pressure	No competent evidence identifies the powder or shows it caused symptoms; Boyd did not ingest the alleged tampered meals	Not met — no admissible evidence of causation or injury; summary judgment for defendants
Whether there is a triable issue on the subjective element (deliberate indifference)	Boyd alleges officers knowingly tampered with his food	Defendants did not act such that a reasonable factfinder could find they actually knew of and disregarded a serious risk	Court did not address subjective element because objective element failed; defendants did not move on subjective element
Official-capacity (Monell) liability against the county or agency	Boyd seeks damages implicating official-capacity relief	No underlying individual-liability verdict; no evidence of policy, custom, or deliberate indifference by the municipality	Dismissed — Monell claims fail where underlying constitutional claim fails
Supplemental jurisdiction over any state-law claims	Boyd could pursue state tort claims arising from the same facts	Federal claims dismissed on summary judgment	Court declined supplemental jurisdiction and dismissed state-law claims without prejudice

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant meets summary judgment burden by identifying absence of genuine dispute)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (materiality and genuine-dispute standards for summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (non-movant must produce specific facts creating a genuine issue)
Strickler v. Waters, 989 F.2d 1375 (4th Cir. 1993) (two-part test for Eighth Amendment conditions claims: objective and subjective)
De'Lonta v. Angelone, 33 F.3d 630 (4th Cir. 1994) (objective prong requires significant injury or substantial risk)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires actual knowledge and disregard of a serious risk)
Shrader v. White, 761 F.2d 975 (4th Cir. 1985) (inmates must be provided nutritionally adequate food prepared safely)
Monell v. Dep't of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipal liability requires policy or custom causing injury)
Lytle v. Doyle, 326 F.3d 463 (4th Cir. 2003) (Monell liability theories explained)
United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (district court may dismiss pendent state claims when federal claims are dismissed)