Shelton Thomas v. Kenneth Cowens, et al

Sep 1, 2026
25-11373

PER CURIAM:

In January 2022, Shelton Thomas, a pro se Georgia prisoner, filed a 42 U.S.C. § 1983 complaint against the personnel of Macon State Prison, raising several claims related to his medical treatment while incarcerated. After three years of litigation, the district court entered summary judgment in favor of the defendants. Thomas now appeals and challenges several aspects of the resolution of his case.

We have considered all arguments raised by Thomas on appeal, including whether:

  1. The district court abused its discretion by denying Thomas‘s motions for spoliation sanctions because the defendants purportedly destroyed video surveillance recordings and sick-call forms relevant to his claims.
  2. The district court erred in finding that Thomas failed to appropriately respond to the defendants’ undisputed statement of material facts in support of their motion for summary judgment, as required by the Middle District of Georgia‘s local rules.
  3. The district court erred in granting summary judgment on Thomas‘s Eighth Amendment deliberate-medical-indifference claims based on its conclusions that: (1) Thomas failed to exhaust his administrative remedies with respect to some of his claims and (2) the defendants were entitled to qualified immunity on the remaining exhausted claims.
  4. The district court erred in granting summary judgment on Thomas‘s First Amendment retaliation claim based on the determination that Thomas failed to establish a constitutional violation and the single defendant named in that count was therefore entitled to qualified immunity.

After careful consideration of the record and the parties’ briefs, we see no reason to disturb the well-reasoned analyses outlined in the relevant orders and recommendations authored by the magistrate judge in this case, as adopted and affirmed by the district judge. Because we find no reversible error in the district court‘s proceedings, we AFFIRM.