Mattox v. State, Department of Corrections
323 P.3d 23
Alaska2014Background
- Richard Mattox, a white inmate at Spring Creek Correctional Center, alleged his cellmate Aaron (Black) repeatedly threatened him and that Aaron’s associates posed a risk.
- Mattox claims he submitted verbal and written transfer requests reporting fear and racial tension; he alleges some written requests are missing from his file.
- Prison staff allegedly responded that there were racial tensions and that Mattox would have to "work it out," but Mattox was not transferred.
- While unguarded and on a TV row with nonworking cameras, Mattox was unexpectedly punched by inmate Vincent Wilkerson (an associate of Aaron), suffering severe facial injuries requiring surgery.
- Mattox sued the State Department of Corrections for negligence in failing to protect him; the superior court granted summary judgment for the Department, finding Mattox’s reported threats too general to make the assault reasonably foreseeable.
- The Alaska Supreme Court reversed, holding that taking Mattox’s evidence as a whole raised a genuine factual dispute about foreseeability and remanded for trial (including issues about lost transfer requests/spoliation).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the DOC owed a duty to protect inmates from assaults by other inmates | Mattox: DOC owes duty to protect from reasonably foreseeable assaults; his reports of threats, racial tension, and fear of roommate/roommate’s friends put DOC on notice | DOC: Duty triggers only on "immediate, identifiable, and specific" threats; general warnings insufficient as a matter of law | Court: DOC has a duty to protect from reasonably foreseeable harm; deliberate-indifference standard (Eighth Amendment) does not replace negligence standard |
| Whether Mattox’s reports made the assault by Wilkerson reasonably foreseeable | Mattox: His complained-to officers about Aaron, Aaron’s friends, racial tensions, and requests to transfer—viewed together—create a genuine issue of foreseeability | DOC: Mattox did not identify Wilkerson or predict the form/time of attack; racial tension allegations too vague to establish foreseeability as a matter of law | Court: Viewing all evidence in Mattox’s favor, a factual dispute exists as to foreseeability; summary judgment was improper |
| Whether the DOC can rely on missing written transfer requests to defeat notice | Mattox: DOC’s loss of his written requests should preclude it from arguing inadequate notice (spoliation/estoppel) | DOC: Disputes existence/contents of written requests; missing docs undermine plaintiff’s proof | Court: Spoliation/estoppel is for trial; for summary judgment, draw reasonable inferences for Mattox and assume he requested a transfer |
Key Cases Cited
- Kalenka v. Jadon, Inc., 305 P.3d 346 (Alaska 2013) (summary judgment reviewed de novo; draw inferences for nonmoving party)
- Wilson v. City of Kotzebue, 627 P.2d 623 (Alaska 1981) (government duty to exercise reasonable care for protection of lives and health)
- B.R. v. State, Dep’t of Corr., 144 P.3d 431 (Alaska 2006) (denying summary judgment where inmate notified DOC of prior sexual assault by employee)
- Joseph v. State, 26 P.3d 459 (Alaska 2001) (foreseeability and scope of duty fact-sensitive; jailer not insurer of inmate safety)
- Sanchez v. State, 784 N.E.2d 675 (N.Y. 2002) (state owes duty to safeguard inmates from fellow-inmate attacks; surprise to victim not dispositive)
- Arctic Tug & Barge, Inc. v. Raleigh, Schwarz & Powell, 956 P.2d 1199 (Alaska 1998) (summary judgment improper when disputed negligence/duty issues remain)
- Grieveson v. Anderson, 538 F.3d 763 (7th Cir. 2008) (distinguishing negligence claims from §1983 deliberate-indifference standard)