Earl Million v. Dawn Grounds
690 F. App'x 163
5th Cir.2017Background
- Plaintiff Earl Raymond Million, a Texas prisoner, sued under 42 U.S.C. § 1983 after an overhead shower exhaust system fell on him at the Telford Unit, injuring him.
- Million alleged defendants (prison officials) were deliberately indifferent to his safety by failing to inspect and maintain the exhaust system.
- Defendants moved for summary judgment; they asserted Eleventh Amendment sovereign immunity (for official-capacity claims) and qualified immunity (for individual-capacity claims).
- District court granted summary judgment dismissing Million’s Eighth Amendment deliberate-indifference claim and his retaliation claim (for failure to exhaust administrative remedies), and denied appointment of counsel.
- Million appealed; the Fifth Circuit affirmed, holding sovereign immunity bars official-capacity damages, qualified immunity shields individual defendants on the facts, and Million failed to exhaust his administrative remedies for the retaliation claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sovereign immunity for official-capacity damages | Million sought money damages against state prison officers | Official-capacity claims are barred by Eleventh Amendment sovereign immunity | Held: Sovereign immunity applies; official-capacity monetary claims dismissed |
| Eighth Amendment deliberate indifference | Failure to inspect/maintain exhaust system created a substantial risk and defendants knowingly disregarded it | Defendants entitled to qualified immunity; no facts show they knew of a substantial risk | Held: No genuine dispute that defendants were deliberately indifferent; qualified immunity applies |
| Failure to exhaust administrative remedies (retaliation claim) | Million argued retaliation claim should proceed | Defendants argued Million did not properly exhaust grievance process | Held: Million failed to exhaust both grievance steps; dismissal with prejudice affirmed |
| Appointment of counsel | Million requested appointed counsel | Defendants opposed; no exceptional circumstances shown | Held: No exceptional circumstances; appointment denied |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate-indifference standard)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step and clearly established law)
- Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with procedural rules)
- Carnaby v. City of Houston, 636 F.3d 183 (summary judgment standard in § 1983 qualified immunity context)
- Mayfield v. Texas Dep’t of Criminal Justice, 529 F.3d 599 (Eleventh Amendment and official-capacity suits against prison officials)
- Frew ex rel. Frew v. Hawkins, 540 U.S. 431 (sovereign immunity principles)
- Jones v. Lowndes Cty., 678 F.3d 344 (plaintiff bears burden to defeat qualified immunity at summary judgment)
- Johnson v. Johnson, 385 F.3d 503 (Texas two-step grievance requirement)