Collins v. Williams
6:18-cv-01491
D.S.C.Sep 27, 2019Background
- Plaintiff Robbie Collins, an SCDC inmate, alleges he suffered broken ribs on April 4, 2018 after an assault and was transferred to McCormick CI on April 10 before receiving treatment.
- On April 10 Collins sought medical care at MCI and was told to submit a sick‑call; on April 11 he told Warden Williams he had a weapon and was placed in restrictive housing (RHU); a 12‑inch sharpened steel weapon was recovered.
- Collins remained in RHU about 50 days (until May 31) and claims he was denied medical treatment (including an x‑ray) for his ribs and denied outdoor recreation, causing physical issues.
- SCDC instituted a systemwide lockdown after a deadly, gang‑related riot at Lee CI on April 15; defendants say no inmates at MCI received outdoor recreation during the lockdown.
- Collins sued alleging denial of medical care and denial of outdoor recreation (other claims were previously dismissed); defendants moved for summary judgment.
- The Magistrate Judge recommended granting summary judgment; the District Court adopted the R&R, finding a factual dispute on exhaustion but granting summary judgment to defendants on the merits of the medical and outdoor‑recreation claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of administrative remedies | Collins contends his grievances were marked as emergency and were not treated as emergencies so exhaustion is lacking | Defendants argue grievances did not reach Warden and were not properly exhausted | Court found a genuine dispute of material fact on exhaustion (Defendants not entitled to judgment on that ground) |
| Deliberate indifference to medical needs | Collins says RHU confinement prevented x‑ray/treatment for broken ribs and constituted deliberate indifference | Defendants show Collins received repeated medical care in RHU, nurse/physician addressed x‑ray request, and Warden lacked notice and could rely on medical staff | Summary judgment for defendants: no deliberate indifference and no supervisory liability for Warden |
| Denial of outdoor recreation (Eighth Amendment) | Collins alleges ~50 days without outdoor recreation caused sores and pain, constituting a serious deprivation | Defendants justify denial by a statewide lockdown after a deadly riot, imposed for safety and applied to all inmates | Summary judgment for defendants: no deliberate indifference and 50‑day denial not an objectively serious deprivation |
| Supervisory liability for Warden | Collins seeks to hold Warden Williams responsible for the alleged deprivations | Defendants: Warden was not aware of need, relied on medical professionals, and implemented lockdown for security | Summary judgment for defendants: Warden not shown to have acted with requisite culpable state of mind |
Key Cases Cited
- King v. Rubenstein, 825 F.3d 206 (4th Cir. 2016) (Eighth Amendment two‑prong test for prison conditions: serious deprivation and deliberate indifference)
- Strickler v. Waters, 989 F.2d 1375 (4th Cir. 1993) (Eighth Amendment analysis for prison conditions)
- Miltier v. Beorn, 896 F.2d 848 (4th Cir. 1990) (standards for supervisory liability in prisoner medical claims)
- Bridges v. Keller, [citation="519 F. App'x 786"] (4th Cir.) (disagreement over medical treatment does not establish deliberate indifference)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden and evidence standards)
- Anderson v. Liberty Lobby, 477 U.S. 242 (standard for genuine issue of material fact at summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmoving party must present specific facts showing genuine issue)
- Thomas v. Ramos, 130 F.3d 754 (7th Cir.) (multi‑week denials of out‑of‑cell exercise may not constitute extreme deprivation)