Qualified Immunity for NY Prison Officials Over Stabbing
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The plaintiff's decedent was stabbed by another inmate (he survived and died later of unrelated causes). The jury awarded $1.00 against prison officials. The court grants defendants' motion for judgment as a matter of law. There was insufficient evidence to support a finding of deliberate indifference. The only argument for the plaintiff was that the assailant was someone with a known general propensity for violence. While the deliberate indifference standard does not require proof of a "specific risk," it does require proof that "whatever the source of the risk, the particular plaintiff entered within the zone of that risk as known to the defendants." (125) The decedent and his assailant had coexisted in each other's presence in general population at least 50 times before. Both prisoners were held in IPC in single cells; there had not been a previous stabbing in that block. Defendants are entitled to qualified immunity anyway because the law in 1991 was unclear as to the level of knowledge required for liability and it was unclear whether prison officials could be held liable solely on the propensity for violence of the attacking inmate. See: Matthews v. Armitage, 36 F.Supp.2d 121 (N.D.N.Y. 1999).