Michael Hunter v. Kelly Mueske, 73 F.4th 561

Michael Hunter, a Wisconsin inmate, was cellmates with Donald Patterson (a known violent inmate) and repeatedly received threats, including being told Patterson would beat him with a cribbage board.
Hunter submitted informal complaints to Unit H supervisor Kelly Mueske (who had housing-assignment authority); at least one informal form was received and, according to Hunter, ignored by Mueske.
Sergeant Tysheme Walker (no housing authority) assisted Hunter by advising and helping him file a formal Inmate Complaint on August 9, 2017; Walker did not file an incident report.
On December 6, 2017, Patterson was reassigned to another cell for unrelated reasons; while Patterson was being moved, Hunter approached Patterson and a violent altercation occurred leaving Hunter injured (video exists).
Hunter sued Mueske and Walker under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference; the district court granted summary judgment for both defendants, and the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walker acted with deliberate indifference	Walker ignored prior threats and failed to report or separate Patterson	Walker proactively helped Hunter file an Inmate Complaint, had no authority over housing, and took reasonable steps	Walker not deliberately indifferent—summary judgment affirmed
Whether Mueske acted with deliberate indifference	Mueske received complaints and did nothing to reassign Hunter away from Patterson	Even if Mueske was indifferent, her inaction did not proximately cause the injury	No liability for Mueske due to lack of causation—summary judgment affirmed
Causation / superseding cause	Mueske’s failure to separate the cellmates foreseeably led to Hunter’s injuries	Hunter’s voluntary approach of Patterson after reassignment was an unforeseeable superseding cause severing liability	Hunter’s decision to approach Patterson was a superseding cause; no proximate causation from Mueske’s conduct

Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (establishes Eighth Amendment deliberate‑indifference standard for inmate safety)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard; genuine dispute required for trial)
Gevas v. McLaughlin, 798 F.3d 475 (7th Cir. 2015) (deliberate‑indifference requires subjective awareness and disregard of excessive risk)
Dobbey v. Mitchell‑Lawshea, 806 F.3d 938 (7th Cir. 2015) (inaction can constitute deliberate indifference)
Burks v. Raemisch, 555 F.3d 592 (7th Cir. 2009) (no free‑floating duty to correct others’ tasks; officials limited by authority)
Roe v. Elyea, 631 F.3d 843 (7th Cir. 2011) (§ 1983 requires proof that defendant’s deliberate indifference caused the injury)
Whitlock v. Brueggemann, 682 F.3d 567 (7th Cir. 2012) (applies tort causation principles, including proximate causation, in § 1983 cases)
Perron ex rel. Jackson v. J.P. Morgan Chase Bank, N.A., 845 F.3d 852 (7th Cir. 2017) (harm caused by intervening factors outside the defendant’s foreseeable risk severs liability)
Exxon Co. U.S.A. v. Sofec, Inc., 517 U.S. 830 (U.S. 1996) (discusses superseding causes and limits on proximate causation)