Orlando Jones v. Ian Wallace, 641 F. App'x 665

Missouri inmate Jones sued Southeast Correctional Center employees under § 1983 for failure to protect him from a serious attack by cellmate JE in December 2012.
District court granted summary judgment to four defendants: Wigfall, Thompson, Hyte, and Wallace.
Jones appeals, arguing these defendants were deliberately indifferent and not entitled to qualified immunity.
Jones and JE were cellmates for about two months; Jones warned staff he needed protective custody (PC).
Jones received assurances that PC requests were being met, but after the attack he claimed Wallace ignored his plea for PC.
The court held these four defendants were entitled to qualified immunity; Jones’s additional ineffective-assistance claim was rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did defendants violate the Eighth Amendment by failing to protect Jones?	Jones argues defendants ignored substantial risk from JE by denying/proceeding with PC.	Defendants contend no substantial risk was proven and no deliberate indifference shown.	No, they are entitled to qualified immunity.
Whether qualified immunity shields Wigfall, Thompson, Hyte, and Wallace from Jones’s claims.	Jones contends defendants were aware of risk and failed to act; immunity should not apply.	Jones failed to show that defendants drew an inference of substantial risk; actions were not clearly unlawful.	Yes, they are entitled to qualified immunity.
Whether Jones provided sufficiently specific information to establish actual knowledge of risk.	Jones notified staff of danger and PC needs; claimed ongoing fear and prior incidents.	Jones did not give specific threats or put JE on an enemy list; information was not specific enough.	No, information was not sufficiently specific to show knowledge of substantial risk.

Jackson v. Everett, 140 F.3d 1149 (8th Cir. 1998) (Eighth Amendment deliberate indifference standard for failure-to-protect claims)
Curry v. Crist, 226 F.3d 974 (8th Cir. 2000) (objective and subjective components of failure-to-protect claims)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires actual awareness of substantial risk)
S.M. v. Krigbaum, 808 F.3d 335 (8th Cir. 2015) (individualized analysis required for qualified immunity)
Robinson v. Cavanaugh, 20 F.3d 892 (8th Cir. 1994) (general fear for safety insufficient to show deliberate indifference)
Prater v. Dahm, 89 F.3d 538 (8th Cir. 1996) (threats between inmates do not automatically establish knowledge of substantial risk)
Young v. Selk, 508 F.3d 868 (8th Cir. 2007) (comparative summary judgment record on protective custody claims)