170 F. Supp. 3d 580
S.D.N.Y.2016Background
- In January 2009 at Green Haven, corrections officers (Benitez, Monzón, Hanaman, Nelson) are alleged to have forced/provoked two fights between plaintiff El’Reko D’Wayne Randle and inmate Melvin Johnson; Johnson later died from injuries.
- Randle alleges officers encouraged the fights, cheered while they occurred in a mantrap, and coordinated a cover-up in incident reports; officers dispute these factual assertions.
- After the fights Randle received a long SHU/solitary sentence and was moved through SHU-based mental-health programs (Clinton GTP, Elmira, Wende) from 2009–2011; he alleges repeated approved transfers out of restrictive care were denied or canceled.
- Randle sued under 42 U.S.C. § 1983 asserting (1) Eighth Amendment claims (excessive force/failure to intervene/failure to protect/unsafe conditions), (2) a § 1983 conspiracy claim, and (3) deliberate indifference to serious mental-health needs against treating and supervisory mental-health/DOCCS officials.
- Defendants moved for summary judgment on exhaustion, merits, and qualified immunity grounds. The court denied summary judgment in full, finding genuine disputes of material fact on presence at the fight, conspiracy/cover-up, supervisory culpability, and deliberate indifference to psychiatric needs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of administrative remedies | Randle exhausted grievances related to the Green Haven fights and reasonably believed grievances over GTP/SHU transfers were non-grievable after CORC refused jurisdiction | Defendants say Randle failed to properly exhaust, did not name individuals, and did not file specific grievances about transfer denials | Court: Grievances about the fights and appeals to CORC suffice; special circumstances excused further exhaustion re: GTP transfers because CORC/superintendent indicated non‑grievability |
| Failure to intervene / excessive force (presence of Nelson; intervening officers) | Randle alleges officers were present/cheered and failed to stop second fight | Defendants maintain some officers (e.g., Nelson) were not present and did not fail to intervene | Court: Genuine factual dispute about presence/actions precludes summary judgment; claim survives |
| Conspiracy & supervisory liability (cover-up; Alexander's role) | Randle alleges officers agreed to force fight and coordinated incident reports; Alexander grossly negligent, coordinated reports, and discouraged discipline | Defendants deny threats/cover-up and argue lack of evidence beyond speculation; supervisory liability unsupported | Court: Circumstantial evidence (threats, joint report writing, Alexander’s conduct) raises triable issues; motions denied on conspiracy and supervisory claims |
| Deliberate indifference to mental-health needs (Marinelli and Mental Health Defs.) | Randle contends Marinelli provided cursory care and ignored suicide history; mental-health officials refused transfers despite treatment-team recommendations, sometimes canceling approved moves (linked to suicide attempts) | Defendants argue care met standards, denials based on security concerns, and no culpable state of mind | Court: Credible disputes over adequacy of care, subjective recklessness, and motive for denying transfers create triable issues; summary judgment denied |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (establishes deliberate indifference standard in prison context)
- Estelle v. Gamble, 429 U.S. 97 (prisoners’ right to medical care under the Eighth Amendment)
- Jones v. Bock, 549 U.S. 199 (PLRA exhaustion; no requirement to name individuals in grievances)
- Hemphill v. New York, 380 F.3d 680 (2d Cir. 2004) (circumstances excusing exhaustion)
- Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (elements for serious medical need and subjective prong)
- Ricci v. DeStefano, 557 U.S. 557 (summary-judgment standard on disputed facts)