Eighth Circuit Upholds Dismissal of Iowa Prisoner's Failure-to-Protect Suit
Eighth Circuit Upholds Dismissal of Iowa Prisoner's Failure-to-Protect Suit
On August 18, 2014, the Eighth Circuit U.S. Court of Appeals affirmed an Iowa district court order which found for the defendants in a lawsuit brought by a prisoner alleging cruel and unusual punishment for prison officials' failure to protect him from repeated attacks.
According to court records, Vincent Walls was incarcerated the Iowa State Penitentiary (ISP) in 2010 when he was attacked three times by fellow prisoners over the course of 18 months. After each incident, Walls declined the prison's offer of protective custody, and he was returned to general population. Walls' repeated requests for a transfer to another prison, however, were denied.
Walls' first fight was with ISP prisoner Raymond Stallings, who Walls said attacked him with a homemade shank. Stallings denied the allegation, yet both prisoners were given infractions, found guilty, and sanctioned with segregation and loss of earned time. About seven months later, Walls and Stallings fought again, this time in the prison yard, and they were again found guilty and given the same sanctions. Walls' third incident occurred about a year later when he fought with ISP prisoner Jamie Voyles. Walls contended that Voyles was acting on behalf of Stallings. Both Walls and Stallings were found guilty and sanctioned with thirty days segregation and thirty days loss of earned time.
Claiming that prison officials failed to protect him from harm, Walls filed suit in the federal district court for the Southern District of Iowa. He claimed prison officials had violated his Eighth Amendment right to be free from cruel and unusual punishment by failing to protect him from Stallings' and Voyles' attacks. After a bench trial, the district court found no constitutional violation, because Walls provided no evidence that his "continued, incarceration at ISP posed a substantial risk of harm." The district court thus denied all requested relief and Walls appealed.
Affirming, the Eighth Circuit found that even if prison officials knew of a substantial risk to Walls' health or safety, they may be found free from liability if they "responded reasonably" to the risk, even if the harm was ultimately not averted.
Not only did ISP officials respond reasonably to Walls' incidents, Walls presented no evidence that prison officials knew of a substantial risk to his health or safety, the court found.
"Prison officials who act reasonably cannot be found liable under the Cruel and Unusual Punishment Clause," wrote the court. "Accordingly, the judgment of the district court is affirmed."
See: Walls v. Tadman, 762 F.3d 778 (8th Cir. 2014).
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Related legal case
Walls v. Tadman
| Year | 2014 |
|---|---|
| Cite | 762 F.3d 778 (8th Cir. 2014) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |