Steven Kulkay v. Tom Roy, 847 F.3d 637

Inmate Steven Kulkay was assigned to work in the Faribault, MN prison industrial workshop and, after ~1 month on the beam saw, severed three fingers and part of a fourth when operating the saw.
The beam saw was designed to use plastic safety guards; Kulkay alleges guards were present in the workshop but never installed.
Kulkay received informal instruction from another inmate but no formal safety training from prison officials; he had not previously used a beam saw.
Kulkay sued the State, the Dept. of Corrections, the commissioner, the facility safety director (Remillard), a supervising safety officer (Schwartz), and unnamed employees under 42 U.S.C. § 1983 (Eighth and Fourteenth Amendments) and asserted negligence/vicarious liability claims.
The district court adopted a magistrate judge’s R&R dismissing claims (including on Eleventh Amendment and qualified immunity grounds); Kulkay appealed only the dismissal of his Eighth Amendment claims against the individual defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to install guards and provide formal training states an Eighth Amendment claim	Kulkay: assignment to the saw without guards or training created a substantial risk of serious harm	Defendants: allegations at most show negligence, not the deliberate indifference required for an Eighth Amendment violation	Held: Allegations fail to show officials had actual knowledge (deliberate indifference); claim not plausible
Whether the individual defendants are entitled to qualified immunity at the pleading stage	Kulkay: factual allegations justify discovery and defeat qualified immunity	Defendants: qualified immunity applies and dismissal is proper before discovery unless clearly established law is alleged	Held: Qualified immunity applies because plaintiff failed first-prong (no plausible constitutional violation); no discovery required

Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference standard: objective risk + subjective actual knowledge)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity protects officials unless they violated clearly established rights)
Pearson v. Callahan, 555 U.S. 223 (2009) (courts may address either prong of qualified immunity first)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (court need not accept legal conclusions as true for Rule 12(b)(6))
Ambrose v. Young, 474 F.3d 1070 (8th Cir. 2007) (Eighth Amendment protection extends to prison work assignments)