Clifton Crumbliss v. Michael Darden
469 F. App'x 325
5th Cir.2012Background
- Crumbliss, a Texas prisoner, filed a pro se § 1983 action against Darden, Bonsu, Gonzales, Negbenebor, and Massie alleging deliberate indifference to safety during transport to his brother’s funeral.
- There were no tie-down straps in the wheelchair van, and Gonzales instructed transport despite this deficiency.
- During transport, Crumbliss’s wheelchair was jostled, causing reinjury to his leg.
- The district court granted summary judgment to the defendants, dismissing Crumbliss’s deliberate-indifference claim with prejudice.
- On appeal, Crumbliss abandoned challenges to Negbenebor and Massie and argued whether Darden, Bonsu, and Gonzales acted with deliberate indifference; the court affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference standard applied? | Crumbliss argues there was a genuine factual dispute. | Darden/Bonsu/Gonzales contend no subjective belief of substantial risk existed. | No genuine dispute; no sufficient evidence of deliberate indifference |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (establishes the deliberate indifference standard)
- Brewster v. Dretke, 587 F.3d 764 (5th Cir. 2009) (deliberate indifference is an extremely high standard)
- Xtreme Lashes, LLC v. Xtended Beauty, Inc., 576 F.3d 221 (5th Cir. 2009) (summary judgment standard on record evidence)
- Brinkmann v. Dallas County Deputy Sheriff Abner, 813 F.2d 744 (5th Cir. 1987) (abrogates recovery against supervisory defendants under Eleventh Amendment immunity)