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11th Circuit Affirms Judgment for Prison Officials in Violence Case

The United States Court of Appeals for the Eleventh Circuit affirmed on April 2, 2014, the lower court's grant of summary judgment for the defendants in a §1983 claim weighed by plaintiff Jody O'Neil Harrison, seeking damages for injuries received at the hands of another prisoner at Holman Correctional Facility in Atmore, Alabama. The other prisoner accosted Harrison on August 6, 2008, in an area of the prison known as 'the back hallway,' and cut Harrison's throat with a razor knife, announcing afterward that he “Just cut a rat's throat.” The knife was never recovered.

Harrison survived to file an Eighth Amendment claim against the warden of the facility, a captain of the guard, and another officer alleging deliberate indifference to the substantial risk of serious harm incumbent to current conditions and policies at the prison. Defendants moved for summary judgment, which was granted in their favor. Harrison appealed to the instance cause.

The complaint alleged deliberate indifference on two fronts: knowingly insufficient security on the back hallway and failure to implement policies overseeing the restriction of knives outside the hobby shop. The magistrate judge ordered defendants to file sworn statement addressing the issues, and to provide copies of records, relevant to policy memorandums, the body of which the judge converted into a motion for summary judgment. Harrison proffered interrogatories to defendants along with motions for future discovery. The interrogatories were ignored without action on the plaintiff’s part and the discovery motions were granted in part, with further recommendation to deny others.

On grant of summary judgment, Harrison appealed on the District Court's abuse of discretion in refusing further discovery. The court of appeals noted that the reports relevant to the issues at bar were submitted and that unless district court committed a clear error in judgment or applied a wrong legal standard that resulted in substantial harm to plaintiff's case, they were reluctant to disturb a lower court's exercise of discretion. The circuit court also ruled prison officials took reasonable measures to insure the safety of the prisoners at Holman Correctional Facility, in particular in the back hallway, where the ratio  of attacks among the population in general and the overall ratio of violent incidents in the back hallway to those in the prison as a whole were low – not reflective of the plaintiff's claim that Holman C.F. was a facility “where violence and terror reign.”

See: Harrison v. Culliver, US Court of Appeals, Eleventh Circuit, Case No. 11-14864 (Decided 2 April 2014).

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Related legal case

Harrison v. Culliver