Thony Beaubrun v. Dodge State Prison
23-12757
| 11th Cir. | Aug 29, 2025Background
- Beaubrun, a former inmate at Dodge State Prison, filed a 42 U.S.C. § 1983 complaint alleging violations of his Eighth and Fourteenth Amendment rights stemming from events at Dodge before his transfer to Riverbend Correctional Facility.
- He alleged prison officials failed to protect him from an inmate attack, were deliberately indifferent to his resulting medical needs, improperly placed him in administrative segregation, and transferred him in retaliation for filing a grievance.
- After screening, the district court dismissed Beaubrun’s complaint for failure to state a claim, concluding his allegations lacked the factual specificity required for constitutional claims.
- On appeal, Beaubrun raised additional claims under the Fourth, Fifth, and Fourteenth Amendments that were not presented to the district court.
- The Eleventh Circuit reviewed the district court’s dismissal de novo under the standards for Rule 12(b)(6) motions.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Failure to protect (Eighth Amendment) | Officials failed to act on his warnings & ignored attacker | Generalized concerns, no specific risk pleaded | Dismissed; no specific or reasonable risk alleged |
| Deliberate indifference to medical need | Officers denied immediate treatment after attack | Officers took him to medical; delay due to shortage | Dismissed; officers acted reasonably, no indifference |
| Procedural due process: segregation | 10-day segregation in extreme heat imposed hardship | No unusually harsh or sentence-extending condition | Dismissed; no atypical/significant hardship shown |
| Procedural due process: transfer | Transfer retaliatory for filing grievance | Inmate has no protected interest in placement | Dismissed; inmate transfer not protected by due process |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for facial plausibility in civil suits)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference test under Eighth Amendment)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to medical needs standard)
- Sandin v. Conner, 515 U.S. 472 (1995) (scope of liberty interests for procedural due process in prison)
- Meachum v. Fano, 427 U.S. 215 (1976) (no liberty interest in avoiding prison transfer)
- Zatler v. Wainwright, 802 F.2d 397 (11th Cir. 1986) (causal connection required for § 1983 liability)