Woodyard v. Alabama Department of Corrections, 700 F. App'x 927

Plaintiff Draper Woodyard, an Alabama inmate, told corrections officer David Leggett that fellow inmate Lawrence Anderson (drunk) threatened to stab him after a dispute over prison "goods." Leggett refused to let Woodyard report the threat to a supervisor or call a supervisor himself.
Woodyard fell asleep (per his version) and was later stabbed by Anderson while in the dormitory; the assault lasted about five minutes, with Woodyard calling for help and suffering multiple stab wounds.
Leggett testified he called for backup during the fight and assistance arrived within 10–15 seconds of his call; Woodyard contends Leggett delayed and watched the assault for some time before calling for help.
Woodyard sued, alleging deliberate indifference under the Eighth and Fourteenth Amendments for (1) failing to prevent the attack after being warned and (2) failing to respond adequately once the assault began. The district court granted summary judgment to Leggett on both claims.
On appeal, the Eleventh Circuit affirmed summary judgment as to the failure-to-prevent claim (qualified immunity: not clearly established) but reversed as to the failure-to-protect-during-the-assault claim, finding genuine factual disputes about Leggett's awareness, delay, and causation and that prior law clearly established immediate action was required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Leggett violate the Constitution by failing to prevent Anderson's pre-assault threat from being carried out?	Woodyard: He warned Leggett of a serious, imminent threat; Leggett ignored it and refused to notify a supervisor.	Leggett: He lacked clearly established duty under controlling precedent to act on this sort of non-gang, possibly intoxicated threat; no deliberate indifference.	Affirmed — even if violation occurred, not clearly established by binding Eleventh Circuit/Supreme Court/Alabama precedent; qualified immunity applies.
Did Leggett violate the Constitution by failing to intervene promptly once the assault began?	Woodyard: Leggett was nearby, heard calls, saw commotion and blood, but delayed calling for help, allowing a multi-minute stabbing.	Leggett: He called for backup and assistance arrived quickly; did not act unreasonably given circumstances.	Reversed — genuine dispute of material fact exists on awareness, delay, and causation; prior law clearly established immediate action was required; summary judgment improper.

Goodman v. Kimbrough, 718 F.3d 1325 (11th Cir. 2013) (standard for viewing facts and deliberate indifference test)
Caldwell v. Warden, FCI Talladega, 748 F.3d 1090 (11th Cir. 2014) (elements of deliberate indifference failure-to-protect claim)
Harrison v. Culliver, 746 F.3d 1288 (11th Cir. 2014) (prison officials must take reasonable steps to protect prisoners)
Marsh v. Butler Cty., 268 F.3d 1014 (11th Cir. en banc 2001) (qualified immunity: need for materially similar precedent)
Rodriguez v. Sec'y for Dep't of Corr., 508 F.3d 611 (11th Cir. 2007) (threats reported to multiple officials and gang context showed subjective knowledge)
United States v. Lanier, 520 U.S. 259 (1997) (general constitutional rules may apply with obvious clarity)
Prater v. Dahm, 89 F.3d 538 (8th Cir. 1996) (threats between inmates are common and do not automatically impute knowledge of substantial risk)
Lebron v. Sec'y, Fla. Dep't of Children & Families, 772 F.3d 1353 (11th Cir. 2014) (inadmissible trial evidence cannot avoid summary judgment)