64 F.4th 1185
11th Cir.2023Background
- Quincy Williams, a Florida inmate, sued under 42 U.S.C. § 1983 alleging (1) Captain Albert Scarpati retaliated for his complaints/grievances by placing him in disciplinary/segregated confinement and ordering cell searches/trashing, and (2) Officer Erick Radford beat him while handcuffed, with Officers Brian Babcock and Cameron Short holding him down and failing to intervene.
- Key incidents: Oct–Dec 2017 — Williams attempted to send legal mail, complained to an assistant warden, was handcuffed and sent to segregation (allegedly without a written disciplinary report); later his cell was searched and trashed; a knife was later found in his pillow and he was charged with possession.
- Williams suffered physical injuries (busted lip, bruises, swollen jaw, loose teeth) after the December transport to segregation and sought medical care; he filed grievances about Scarpati and the treatment he received.
- The district court granted summary judgment for Scarpati, Radford, Babcock, and Short. The magistrate judge’s report emphasized the disciplinary finding on the knife and credited defendants’ explanations for segregation and the search.
- The Eleventh Circuit vacated summary judgment except as to the retaliation claim based on the planted knife (affirmed): it held genuine issues of material fact exist as to (a) two retaliation claims (placement in segregation and search/trashing of the cell), (b) Radford’s excessive-force claim, and (c) Babcock/Short’s failure-to-intervene claim; the planted-knife retaliation claim fails under O’Bryant because Williams received due process and the hearing found possession supported by evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retaliation — placement in disciplinary/segregated confinement | Williams: he was sent to segregation after complaining to assistant warden; Scarpati told him he could lock him up for grievances | Scarpati: placement was for violating protocol and being disorderly; not motivated by protected speech | Vacated summary judgment — triable issue on motivating causal link (survives summary judgment) |
| Retaliation — search and trashing of cell | Williams: officers trashed his cell, told him to stop writing Scarpati up, and said Scarpati ordered the search | Scarpati: the search was random; no causal link to grievances | Vacated summary judgment — triable issue on causation and pretext |
| Retaliation — knife planted / possession charge | Williams: officers planted a knife to subject him to discipline | Scarpati: Williams received a disciplinary hearing and was found guilty based on evidence | Affirmed for defendants — O’Bryant bars a retaliation claim once inmate was afforded due process and hearing supported by evidence |
| Eighth Amendment — excessive force by Radford | Williams: while handcuffed and restrained he was slammed into a wall, punched repeatedly, choked, and injured | Radford: denies using force or contends force was needed to restore order due to disorderly conduct | Vacated summary judgment — genuine issue of fact under Campbell/Whitley/Wilkins; for jury to decide |
| Failure-to-intervene — Babcock & Short | Williams: they held him while Radford beat him and failed to stop it | Defendants: there was no underlying excessive-force violation, so no duty to intervene | Vacated summary judgment — remanded because excessive-force claim survives summary judgment |
Key Cases Cited
- O’Bryant v. Finch, 637 F.3d 1207 (11th Cir. 2011) (retaliation claim barred when inmate was found guilty after due process and panel’s finding was supported by evidence)
- Wilkins v. Gaddy, 559 U.S. 34 (2010) (test whether force was applied in good-faith to maintain discipline or maliciously/sadistically to cause harm)
- Campbell v. Sikes, 169 F.3d 1353 (11th Cir. 1999) (five-factor framework for excessive-force analysis)
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (1977) (burden-shifting: protected conduct as motivating factor then defendant must show same action would have occurred)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard — reasonable jury could return verdict)
- Smith v. Mosley, 532 F.3d 1270 (11th Cir. 2008) (elements of prisoner retaliation claim)
- Wright v. Newsome, 795 F.2d 964 (11th Cir. 1986) (search of cell and destruction of property can support retaliation claim)
- Velazquez v. City of Hialeah, 484 F.3d 1340 (11th Cir. 2007) (liability for officers who fail to intervene to stop excessive force)
- Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (applies Mt. Healthy burden-shifting in prison retaliation context)
- United States v. Stein, 881 F.3d 853 (11th Cir. 2018) (self-serving affidavit based on personal knowledge can create factual dispute at summary judgment)