Ceasar Shannon v. Darrel Vannoy
682 F. App'x 283
| 5th Cir. | 2017Background
- Ceasar Shannon was housed at Dixon Correctional Institute for over three years in a cell with a large hole in the ceiling that leaked when it rained.
- Inmates repeatedly complained and submitted maintenance requests; guards used five-gallon buckets to catch water.
- On May 28, 2014, rainwater leaked onto the floor; Shannon slipped while going to the bathroom at night and injured his back, shoulder, and hip.
- Shannon sued under 42 U.S.C. § 1983 alleging prison officials were deliberately indifferent to his health and safety in violation of the Eighth Amendment.
- The State moved to dismiss under Rule 12(b)(6), arguing slip-and-fall allegations are ordinary negligence not actionable under § 1983; the district court granted dismissal and Shannon appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the leaking ceiling and resulting slip-and-fall state an Eighth Amendment claim for deliberate indifference to prison conditions | Shannon: Officials knew of the leak, did not fix it, and that indifference exposed him to an unreasonable risk of harm | State: The allegations describe negligence/unsafe conditions (a slip-and-fall) not constitutionally cognizable deliberate indifference under § 1983 | The court held Shannon’s facts are insufficient to show the deprivation was objectively serious or that officials acted with deliberate indifference; dismissal affirmed |
Key Cases Cited
- Hines v. Alldredge, 783 F.3d 197 (5th Cir. 2015) (standard for Rule 12(b)(6) review and pleading plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must state facts showing claim is plausible)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for prison conditions claims)
- Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment applies to prisoner safety and conditions)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (Constitution does not require comfortable prisons but forbids inhumane ones)
- Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) (extreme deprivations of basic needs violate the Eighth Amendment)
- Davis v. Scott, 157 F.3d 1003 (5th Cir. 1998) (defining minimal civilized measure of life’s necessities)
- Cotton v. Taylor, 176 F.3d 479 (5th Cir. 1999) (minimally safe housing as Eighth Amendment requirement)
- Beck v. Lynaugh, 842 F.2d 759 (5th Cir. 1988) (conditions like unchecked cold and water puddles can state an Eighth Amendment claim)