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Michigan Prisoner Wins $20,000 on Failure to Protect Claim

On March 29, 2006, a federal court in Michigan awarded $20,000 to a state prisoner who was attacked and cut with a razor after prison officials repeatedly ignored his requests for protection.

Reggie Williams, a prisoner serving 2 to 15 years in the Massachusetts Department of Corrections since 1999, claimed that on June 14, 2000, he was transferred from another prison to the Gus Harrison Correctional Facility in Adrian. On the prison yard the next day Williams encountered another prisoner, Kevin Stepney, with whom hed had an altercation in 1985 at the Wayne County Jail. Williams was accused of sexually assaulting Stepney who is serving a 60 to 90 year sentence after their 1985 fight, but the charges were later dropped.

After seeing Stepney, Williams went to Doug Wells, the Assistant Resident Unit Supervisor, and asked to be placed in protective custody. Williams told Wells of the fight in county jail and said that Stepney had made veiled threats against him on the recreation yard. Wells refused to move Williams claiming there was not enough information. The situation continued to escalate. Williams even skipped meals to avoid Stepney, he claimed.
Williams talked to Wells a second time on June 16 and again on June 26.
Wells merely opined that Stepney would not attack him because he was bigger. (Williams is roughly 6 4 and 300 pounds; Stepney is 5 10 and 170 pounds.) Williams ultimately went to Wells immediate supervisor and the warden, but neither took any action.

Williams talked to Wells again on July 3. On July 4 Stepney attacked him with a weapon made from razor blades melted into a toothbrush. As Stepney stabbed at him, Williams turned and was cut on the back. Stepney then turned and ran. Williams was treated in the infirmary for a superficial cut. The wound took 3 weeks to heal and left a 6 to 9 inch scar.

Williams sued Wells under 42 U.S.C. § 1983 for failing to protect him from Stepney. Along with the physical injury Williams claimed he is now afraid to have other prisoners stand behind him and that he has trouble sleeping in open areas. He was still seeing prison mental health workers when the bench trial was held on December 13-14, 2005.

At trial in the U.S. District Court for the District of Eastern Michigan, Judge J. Roberts held that Williams met the requirements for proving a violation of the Eighth Amendments proscription against cruel and unusual punishment.

To prove an Eighth Amendment claim for failure to prevent harm, a prisoner must show that prison officials were deliberately indifferent. Deliberate indifference, in turn, requires a showing of sufficiently serious risk and a sufficiently culpable state of mind. In Williams case, the threat of bodily injury satisfied the first prong, Judge Roberts held. The second prong was also satisfied because, according to Roberts, Wells had actual knowledge that Williams faced a substantial risk of serious harm.
Additionally, Roberts noted that Wells refusal to immediately place Williams in protective custody after requested it directly contradicted MDOC Policy Directive 04.05.120(T).

Based on the above, Roberts awarded Williams $4,000 in compensatory damages and $16,000 in punitive damages. Total award: $20,000. Roberts also held that Williams was entitled to attorneys fees. Williams was represented by Carl H. Von Ende of Detroit. See: Williams v. Wells, USDC ED MI, Case No. 02-74530.

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Related legal case

Williams v. Wells