David Reedy v. Michael West, 988 F.3d 907

In 2016 prisoner David Reedy and cellmate Oscar Hensley were housed together; relations were largely nonviolent but strained (different races, personal habits) and Reedy requested a cell change.
Reedy alleges Hensley made threats in late June/early July and that Reedy told prison counselor Michael West in two brief (≈60-second) conversations—July 13 and July 19—that he feared for his safety and wanted to be moved; Reedy gave no detailed descriptions of threats.
West was not Reedy’s assigned counselor, had limited contact with both men, and (per his account) treated the dispute as a cohabitation conflict and told them to resolve it.
On July 20 Hensley assaulted Reedy with a rock, causing serious injury; Reedy sued West under 42 U.S.C. § 1983 for Eighth Amendment failure-to-protect, alleging West was deliberately indifferent.
The magistrate judge recommended denying West summary judgment; the district court rejected that and granted summary judgment for West on qualified immunity grounds; Sixth Circuit affirmed.
The court emphasized lack of objective evidence of a substantial risk (no history of prior violence or specifics) and lack of subjective knowledge by West (vague complaints and minimal contact); inmate affidavits were deemed conclusory or inadmissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Reedy was objectively incarcerated under conditions posing a substantial risk of serious harm	Reedy: Hensley threatened him, Reedy repeatedly requested a room change, so a substantial risk existed	West: No history of violence; relationship was mostly nonconfrontational; complaints were vague	Court: No — Reedy failed to show specific facts establishing a substantial risk
Whether West was deliberately indifferent (subjective knowledge and failure to abate risk)	Reedy: He told West he feared for his safety; West minimized the concern and encouraged Hensley	West: Had minimal contact, did not draw inference of substantial risk, reasonably treated it as a cohabitation dispute	Court: No — no evidence West was subjectively aware of a substantial risk or recklessly disregarded it
Whether West is entitled to qualified immunity	Reedy: Eighth Amendment violated by failure to protect	West: No constitutional violation, so qualified immunity applies	Court: Yes — because no constitutional violation, West entitled to qualified immunity; summary judgment affirmed

Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment failure-to-protect standard: objective risk + subjective deliberate indifference)
Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (qualified immunity two-step framework)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity doctrine)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard re: evidence and admissibility)
Tolan v. Cotton, 572 U.S. 650 (2014) (crediting nonmovant's evidence on summary judgment when appropriate)
Scott v. Harris, 550 U.S. 372 (2007) (no genuine issue when record could not lead a rational trier of fact to find for nonmoving party)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment and the requirement of more than metaphysical doubt)
Beck v. Hamblen Cty., 969 F.3d 592 (6th Cir. 2020) (discussion of summary judgment review and Eighth Amendment standards)
Bishop v. Hackel, 636 F.3d 757 (6th Cir. 2011) (examples of circumstances satisfying objective/subjective elements)
Lujan v. Nat'l Wildlife Fed'n, 497 U.S. 871 (1990) (conclusory allegations insufficient to create a genuine factual dispute)
Alexander v. CareSource, 576 F.3d 551 (6th Cir. 2009) (summary judgment requires more than mere hope of discrediting opposing evidence)
Greene v. Bowles, 361 F.3d 290 (6th Cir. 2004) (evidence of particular vulnerability or assailant's history can establish risk and knowledge)