Lindell Tate v. Lindsay, 20-2820

Plaintiff Lindell Tate, a pro se prisoner formerly at SCI Somerset, alleged a failure-to-protect claim under the Eighth Amendment against CO Faultz and Lt. Lindsay.
Tate repeatedly told Faultz and, later via intercom, Lindsay that he and his cellmate were having escalating, violent disputes and requested a cell transfer; Faultz said he would "work on it," then deferred to the lieutenant.
During an intercom call, Tate and his cellmate both threatened that "something was going to happen" if one of them was not moved; Lindsay told them that if both would not move, neither could, and the cellmate refused to move while Faultz stood outside the cell.
Mid‑afternoon the cellmate attacked Tate, choked him until he lost consciousness, and bound his hands and feet; Tate suffered a busted lip and was later moved and given medical care; the assailant received disciplinary sanctions.
The District Court dismissed Tate’s complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A for failure to state a claim, finding the injury de minimis; Tate appealed.
The Third Circuit reviewed de novo, accepted Tate’s allegations as true for pleading purposes, and vacated and remanded, holding Tate plausibly pled deliberate indifference and more‑than‑de minimis injury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tate pleaded an Eighth Amendment failure‑to‑protect claim	Tate alleged officials knew of an escalating dispute, declined to isolate him after offering to move both, and his injuries followed	Officials argued they reasonably balanced credibility and refused transfers; no deliberate indifference pleaded	Reversed: allegations plausibly show officials knew and disregarded a substantial risk and caused harm
Whether Tate’s injuries were de minimis	Tate claimed he was choked into unconsciousness and bound; lip injured	District Court reduced injury to a mere "busted lip" and treated it as de minimis	Court held injuries (loss of consciousness and restraints) were more than de minimis
Whether withdrawing remedial offer when cellmate refused to move can show indifference	Tate said withdrawal left him trapped in a volatile, escalating situation	Defendants relied on discretion to decline protective custody absent credible fear or when the other inmate refuses	Court found defendants’ conduct (offering to move both, then leaving Tate) could plausibly constitute deliberate indifference

Farmer v. Brennan, 511 U.S. 825 (1994) (establishes Eighth Amendment deliberate‑indifference standard)
Bistrian v. Levi, 696 F.3d 352 (3d Cir. 2012) (elements for failure‑to‑protect claim against prison officials)
Young v. Quinlan, 960 F.2d 351 (3d Cir. 1992) (recognizes difficulty for officials distinguishing genuine protective custody requests and need to investigate credibility)
Warren Gen. Hosp. v. Amgen, Inc., 643 F.3d 77 (3d Cir. 2011) (pleading standard: accept factual allegations as true and construe in plaintiff's favor)