Stephen Walker v. Joe Nunn, 456 F. App'x 419

Walker, a Texas prisoner, filed a 42 U.S.C. § 1983 action alleging Eighth Amendment sleep deprivation at the Rufe Jordan Unit.
Defendants included the unit warden, TDCJ directors, and several unit officials in various capacities.
The district court granted summary judgment and dismissed Walker's suit with prejudice after an evidentiary hearing.
The court applied de novo review for summary judgment and required Walker to show genuine material facts to survive.
Walker argued three confinement conditions—prison schedule, noise, and staff misconduct—combined to deprive sleep; he asserted deliberate indifference.
The Fifth Circuit affirmed, holding no genuine issue of material fact showed a constitutional violation or supervisory liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the schedule deprive Walker of sleep as an objective risk?	Walker contends the schedule prevented sleep.	Nunn says schedule is reasonably related to penological interests and sleep time is protected but feasible.	No genuine issue; schedule reasonably related to legitimate interests.
Was there a conscious disregard of a sleep-related risk due to noise levels?	Noise readings understate actual conditions and ACA standards are irrelevant to liability.	No widespread grievances; testing plus ACA compliance support reasonable response.	No deliberate indifference; evidence shows reasonable reliance on testing and ACA standards.
Did staff misconduct and failure to supervise constitute deliberate indifference?	Staff wakes and harassment went unaddressed and grievances were ignored.	Responses to grievances showed investigations or corrective action; no causal link shown.	No supervisory liability; no evidence of failure to train/supervise causing violation.
Did Walker demonstrate a policy or deliberate indifference through supervisory policy?	Defendants had a policy depriving inmates of sleep and ignoring complaints.	No admissible evidence of such policies; conclusory assertions insufficient.	No policy shown; no deliberate indifference established.

Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for Eighth Amendment)
Wilson v. Seiter, 501 U.S. 294 (1991) (objective and subjective components of confinement conditions)
Helling v. McKinney, 509 U.S. 25 (1993) (sleep deemed a basic need in Eighth Amendment analysis)
Gates v. Cook, 376 F.3d 323 (5th Cir. 2004) (consideration of conditions in combination; ACA standards relevance)
Turner v. Safley, 482 U.S. 78 (1987) (prison regulations must be reasonably related to legitimate penological interests)
Talib v. Gilley, 138 F.3d 211 (5th Cir. 1998) (balancing standard for penological interests in scheduling)
Duffie v. United States, 600 F.3d 362 (5th Cir. 2010) (summary judgment burden and evidence standard)
Alpine View Co. v. Atlas Copco AB, 205 F.3d 208 (5th Cir. 2000) (courts uphold reasonable discovery rulings; procedural discretion)
Thompkins v. Belt, 828 F.2d 298 (5th Cir. 1987) (supervisory liability requires a causal link and inadequate supervision)