Trevis Caldwell v. Warden, FCI Talladega
2014 U.S. App. LEXIS 6367
| 11th Cir. | 2014Background
- Caldwell, an inmate at FCI-Talladega, was assaulted by his cellmate Pinson in the SMU.
- Pinson had a long history of violence and was placed in the SMU for better management.
- Caldwell was assigned to share a cell with Pinson on August 18, 2009; Pinson had earlier requested a cellmate removal.
- After a cell fire started by Pinson on Sept. 9, 2009, Caldwell was rescued and examined medically; his property was damaged.
- Caldwell informed Elston, Williams, and Davis that returning him to the cell would risk his life; they failed to address his safety concerns.
- District court granted summary judgment to defendants; on appeal the court vacated and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the defendants violated Caldwell’s Eighth Amendment rights | Caldwell asserts they knew of Pinson’s risk and returned him to the cell | Elston/Williams/Davis argue no reversible risk or lack of deliberate indifference | Yes; genuine issue exists as to subjective knowledge and risk |
| Whether the defendants are entitled to qualified immunity | The right clearly established by Cottone and related cases | There was no clearly established law at the time that would preclude their actions | No; not entitled to qualified immunity at summary judgment due to clearly established law |
| Whether Caldwell must show actual knowledge of risk via exact actions by defendants | Circumstantial evidence supports actual knowledge of risk | Need precise showing of awareness of risk | Evidence supports subjective knowledge inference; jury could find actual knowledge |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (premise of deliberate indifference for substantial risk of harm)
- Cottone v. Jenne, 326 F.3d 1352 (11th Cir. 2003) (duty to monitor/mitigate known risk; clearly establishes knowledge standard)
- Hale v. Tallapoosa Cnty., 50 F.3d 1579 (11th Cir. 1995) (knowledge of risk and failure to act violation)
- LaMarca v. Turner, 995 F.2d 1526 (11th Cir. 1993) (deliberate indifference via failure to monitor risk)
- Rodriguez v. Sec’y for Dep’t of Corrs., 508 F.3d 611 (11th Cir. 2007) (circumstantial evidence supports finding of knowledge of risk)
- Hollman ex rel. Hollman v. Harland, 370 F.3d 1252 (11th Cir. 2004) (knowledge and risk assessment standards in qualified immunity)
- Coffin v. Brandau, 642 F.3d 999 (11th Cir. 2011) (clearly established law inquiry; en banc discussion)