William Cook, II v. State of Tennessee, W2016-01914-COA-R3-CV

William Cook, II (plaintiff) was stabbed by his cellmate Chad Morrison at West Tennessee State Penitentiary on Dec. 6, 2010; Cook alleged severe injuries from a shank assault.
Cook sued the State in the Tennessee Claims Commission alleging negligence: prison staff knew or should have known of Morrison’s dangerous propensities and failed to protect or warn Cook.
Morrison had been classified as minimum security upon transfer and had no documented history of institutional violence; Sullivan County Jail’s intake likewise recorded no violent history.
Cook and Morrison were cellmates from Oct. 21–22, 2010 until the assault; Cook admitted they had a good relationship, he never felt threatened, never complained, and never requested reassignment.
Cook pointed to two institutional incidents: an instructor caught Morrison attempting to take a piece of steel from the prison school (leading to removal from the program) and an instance where staff allegedly found Morrison with a knife; neither resulted in disciplinary findings showing a pattern of violent institutional behavior.
The Claims Commissioner granted the State’s summary judgment motion, concluding Cook failed to raise a genuine issue that the assault was reasonably foreseeable (proximate cause); this appeal affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the assault was reasonably foreseeable such that the State breached a duty to protect Cook	Cook: prior incidents (steel removal, prior knife possession) put WTSP on notice of Morrison’s dangerous propensity, creating foreseeability and proximate cause	State: Morrison had no violent history, incidents were remote/confiscated/undocumented, and Cook never complained or showed any specific risk; thus no prior notice and no foreseeability	Held: No genuine issue of material fact; assault was not a reasonably foreseeable probability and summary judgment for the State affirmed

Rye v. Women's Care Ctr., MPLLC, 477 S.W.3d 235 (Tenn. 2015) (summary-judgment standard and de novo appellate review)
Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (summary-judgment principles)
Hunter v. Brown, 955 S.W.2d 49 (Tenn. 1997) (appellate review of summary judgment)
Godfrey v. Ruiz, 90 S.W.3d 692 (Tenn. 2002) (construing evidence in favor of nonmoving party)
Byrd v. Hall, 847 S.W.2d 208 (Tenn. 1993) (materiality and genuine-issue standards)
McClenahan v. Cooley, 806 S.W.2d 767 (Tenn. 1991) (three-pronged proximate-cause test)
King v. Anderson County, 419 S.W.3d 232 (Tenn. 2013) (duty of penal institutions and foreseeability/prior-notice requirement for inmate-on-inmate assaults)
Kilpatrick v. Bryant, 868 S.W.2d 594 (Tenn. 1993) (policy limits on legal responsibility in proximate-cause analysis)
Hale v. Ostrow, 166 S.W.3d 713 (Tenn. 2005) (limits on liability where harm not reasonably foreseeable)
Carr v. Borchers, 815 S.W.2d 528 (Tenn. Ct. App. 1991) (burden-shifting when affirmative defense supports summary judgment)