McFarland v. Brooks, 4:14-cv-00090

Plaintiff Takei McFarland, a Mississippi State Penitentiary inmate, worked in the prison poultry facility from Oct. 2013 to Apr. 2014 and sued under 42 U.S.C. § 1983 alleging Eighth Amendment conditions-of-confinement claims.
Site inspections and a Mississippi State University extension report documented extensive disrepair: ruptured water lines, exposed wiring, holes in walls/roofs, flooded floors with several feet of manure-feed-carcass slurry, rodents, insects, and poor ventilation/lighting.
McFarland submitted verified unsworn declarations describing exposure to manure slurry (including fecal contact to face), lack of protective gear, near-electrocution, cold exposure, flies/maggots/rodents, a rash, loss of leg hair, and a back injury (stepping into a hidden hole) for which he sought medical care.
Defendants named in the surviving claims are Stanley Brooks (Director of Agricultural Enterprise), Ed Cole (farm manager), and Henry Gipson (inmate supervisor); Richard Gipson (Fire & Safety Director) was later conceded by plaintiff.
Procedural posture: After a Spears hearing the court narrowed the case to individual-capacity Eighth Amendment claims against Brooks, Cole, and Henry; defendants moved for summary judgment asserting sovereign immunity, qualified immunity, and failure to state a claim. The court granted summary judgment as to Richard, denied sovereign-immunity argument as moot, denied qualified-immunity without prejudice, and denied summary judgment on other grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Sovereign immunity for official-capacity claims	McFarland says only individual-capacity claims remain	Defendants assert Eleventh Amendment immunity for official-capacity monetary claims	Court: Official-capacity claims not before court; sovereign-immunity motion denied as moot
2. Qualified immunity (individual-capacity)	McFarland alleges personal involvement in unsafe conditions; immunity inapplicable	Defendants pleaded qualified immunity in answer and seek summary judgment	Court: Defendants failed to carry initial burden to show they acted within discretionary authority; qualified-immunity denied without prejudice (recording left open for future assertion)
3. PLRA §1997e(e) / physical-injury requirement	McFarland alleges back injury from stepping into hole and medical treatment; also rash and other symptoms	Defendants argue no significant physical injury shown; emotional damages barred without physical injury; rash/nightmares de minimis	Court: Genuine factual dispute exists about back injury (possible aggravation of scoliosis and repeated medical care); PLRA does not bar non-compensatory relief; summary judgment on this ground denied
4. Claim against Richard Gipson	N/A (claims filed)	Defendants moved for summary judgment	Court: McFarland conceded claims against Richard; summary judgment granted as to Richard

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Norwegian Bulk Transp. A/S v. Int'l Marine Terminals P'ship, 520 F.3d 409 (5th Cir.) (summary judgment standard clarification)
Camreta v. Greene, 131 S. Ct. 2020 (qualified immunity principles)
Alexander v. Tippah Cty., 351 F.3d 626 (5th Cir.) (PLRA §1997e(e) physical-injury must be more than de minimis)
Cruz v. Beto, 603 F.2d 1178 (5th Cir.) (broad discretion of prison administrators)
Williams v. Treen, 671 F.2d 892 (5th Cir.) (qualified immunity: burden to show discretionary authority)