Williams v. Miller, 696 F. App'x 862

Background

Mario Williams, an Oklahoma state prisoner, sued CCA and prison officials under § 1983 alleging RLUIPA, First Amendment (free exercise), Eighth Amendment (denial of medical care), and state-law claims; district court granted summary judgment to defendants and dismissed some claims; Williams appealed only First and Eighth Amendment rulings.
Williams, a Muslim classified maximum-security, was barred from participating in group worship (Jumu’ah) because maximum-security inmates are confined to cells ~23 hours/day and escorted/handcuffed when out for safety reasons.
Prison security staff (via affidavit of John Hilligoss) justified the no‑group‑worship policy on safety, security, and resource grounds; district court found the policy substantially burdened Williams’ faith but upheld it under Turner as justified by penological interests.
Williams sought repeat x‑rays and treatment for finger/wrist injuries (from earlier injury) and for knee/left wrist based on earlier PA recommendations; some imaging and conservative treatment were provided; repeat x‑rays eventually showed healed finger fractures and wrist x‑rays were negative.
Williams initiated a hunger strike to pressure for imaging; staff did not move him to the medical unit until June 5 when he fell and was then monitored and treated; Williams alleged failure to follow hunger‑strike protocol and that administrators (Warden Miller and HSA Sellers) were deliberately indifferent.
The district court concluded medical staff were not deliberately indifferent, supervisory defendants lacked personal participation/knowledge, and any policy violations did not amount to constitutional violations; the Tenth Circuit dismissed Williams’ appeal as frivolous, denied IFP on appeal, imposed a filing‑fee requirement and a strike under 28 U.S.C. § 1915(g).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment — prohibition on group worship for maximum‑security inmates	Williams: ban on Jumu’ah substantially burdens his sincerely held religious belief and defendants offer only speculative/exaggerated security reasons	Defendants: policy is rationally related to legitimate penological interests (safety, security, resources); alternatives (in‑cell worship) available; Turner factors satisfied	Court: Found substantial burden but policy justified under Turner; summary judgment for defendants affirmed
Eighth Amendment — denial/delay of medical care for fingers and right wrist	Williams: Sellers and CCF medical staff denied appropriate diagnostics/treatment and delayed care (wanted MRI/rx)	Defendants: staff provided reasonable, conservative care; relied on earlier negative x‑rays; later imaging showed healed fractures; supervisory defendants did not personally participate	Court: Medical response was reasonable; no deliberate indifference by providers or supervisors; summary judgment affirmed
Eighth Amendment — denial of Warford’s recommended treatment for knee/left wrist	Williams: Sellers improperly denied prior PA’s recommendations (referral/surgery)	Defendants: Sellers relied on more current provider (Dr. Reiheld); disagreement over treatment choice not an Eighth Amendment violation	Court: Disagreement over course of treatment insufficient for deliberate indifference; Sellers’ reliance on later diagnosis reasonable; summary judgment affirmed
Eighth Amendment — failure to monitor during hunger strike / supervisory liability	Williams: Sellers and Miller knew or should have known of hunger strike per policy and failed to timely move/monitor him	Defendants: No evidence either supervisor actually knew; staff reasonably believed Williams was not on strike until later due to commissary/observations; even policy violation isn’t constitutional violation; Miller’s grievance response not personal participation	Court: No evidence of requisite subjective knowledge or personal participation; supervisory liability not shown; summary judgment affirmed

Key Cases Cited

Kay v. Bemis, 500 F.3d 1214 (10th Cir.) (prison regulation analysis under First Amendment constraints)
Turner v. Safley, 482 U.S. 78 (1987) (four‑factor test for assessing reasonableness of prison regulations that impinge constitutional rights)
O’Lone v. Estate of Shabazz, 482 U.S. 342 (1987) (prison safety can justify burdens on free exercise rights)
Hammons v. Saffle, 348 F.3d 1250 (10th Cir. 2003) (maintaining prison order/safety is legitimate penological interest)
Martinez v. Beggs, 563 F.3d 1082 (10th Cir. 2009) (subjective component of deliberate indifference requires actual knowledge of excessive risk and disregard)
Callahan v. Poppell, 471 F.3d 1155 (10th Cir. 2006) (disagreement over course of treatment does not establish Eighth Amendment violation)
Gallagher v. Shelton, 587 F.3d 1063 (10th Cir. 2009) (denial of a grievance, absent connection to violation, does not show personal participation for § 1983)
Serna v. Colo. Dep’t of Corrs., 455 F.3d 1146 (10th Cir. 2006) (supervisory § 1983 liability requires showing subordinates violated the constitution)
Trigalet v. City of Tulsa, 239 F.3d 1150 (10th Cir. 2001) (municipality cannot be held liable when employees committed no constitutional violation)
Neitzke v. Williams, 490 U.S. 319 (1989) (definition of frivolous pleadings/appeals under federal law)
DeBardeleben v. Quinlan, 937 F.2d 502 (10th Cir. 1991) (IFP appeals standard regarding nonfrivolousness)