Freddie Nelson v. Josh Henthorn, 677 F. App'x 823

Prisoner Freddie Nelson, housed at St. Mary’s Correctional Center, shared a cell with Joshua Humphrey and Gordon Bays.
On April 13, 2013, Humphrey threatened to beat Nelson and Bays (sexual offenders) and said he would "get them when they go for chow." Nelson and Bays reported the threats.
Captain Josh Henthorn investigated, interviewed the parties around midnight, moved Humphrey to another cell, and told Nelson Humphrey would be transferred to a different facility.
The next evening Humphrey encountered Nelson in a yard area with limited guard sightlines, called him a "big mouth," and led an attack by a group of inmates that left Nelson with a serious facial fracture and ongoing injuries.
Nelson sued under 42 U.S.C. § 1983 claiming Henthorn was deliberately indifferent in violation of the Eighth Amendment; the district court dismissed and granted qualified immunity; the Fourth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Henthorn was deliberately indifferent to a substantial risk to Nelson	Nelson: Henthorn knew Humphrey intended to kill him (including outside the cell) but failed to take additional measures	Henthorn: He reasonably investigated, moved Humphrey from the cell, and did not know of a substantial risk in common areas	Court: No deliberate indifference; removing Humphrey from the cell was reasonable under the circumstances
Whether Henthorn violated a clearly established Eighth Amendment right (qualified immunity)	Nelson: Right to protection was clearly established given the threats	Henthorn: His conduct did not violate clearly established law because his steps were reasonable	Court: Henthorn entitled to qualified immunity because no constitutional violation shown

Harlow v. Fitzgerald, 457 U.S. 800 (establishes qualified immunity standard)
Pearson v. Callahan, 555 U.S. 223 (courts may decide constitutional violation or clearly-established prong first)
Saucier v. Katz, 533 U.S. 194 (framework for qualified immunity analysis)
Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate-indifference standard in prisons)
Makdessi v. Fields, 789 F.3d 126 (4th Cir. standard applying Farmer in prison-protection context)
Brice v. Va. Beach Corr. Ctr., 58 F.3d 101 (circumstantial evidence may show official’s knowledge when risk is obvious)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for Rule 12(b)(6) dismissals)