Illinois state prisoner Lincoln Lee had a bad feeling about his new cellmate, who was bigger and younger than him, and prone to repeated verbal threats. The Illinois River Correctional Center, like most state prisons, was overcrowded – so requests for cell changes to avoid possible conflicts were typically met with indifference. However, Lee argued that the Eighth Amendment required prison officials to protect him from the fight he knew was coming.
On October 15, 2010, Lee told a counselor named Jay Shepler that based upon repeated death threats from his cellmate, he wanted to be moved to a different cell. The counselor turned his request over to internal affairs, but Lee was not moved and remained in the cell with the same prisoner who had threatened him.
Lee tried again, asking another guard for a transfer. The guard said he would have to submit a written request, but that if Lee felt he was in imminent danger of harm, he could be moved out of general population and placed in a segregation cell. Lee declined to be put in segregation and was assaulted by his cellmate shortly thereafter.
In the ensuing brawl, Lee was injured. He then filed a federal civil rights suit, prepared all of his own pleadings and discovery requests, and was appointed a pro bono attorney only for trial.
In both the discovery and trial process, prison officials admitted that Lee had advised them of his fear of physical harm and that prison staff were on notice, thereby triggering their duty to protect him. In denying the defendants’ motion to dismiss, the district court followed the case of Farmer v. Brennan, 511 U.S. 825 (1994) [PLN, July 1994, p.1], stating that Lee had proven “actual knowledge of impending harm by showing that he complained to prison officials about a specific threat to his safety.”
The defendants’ motion for summary judgment was denied and, following a jury trial in September 2014 where the appointed attorney used inconsistent responses by prison officials to impeach their testimony, Lee received $75,000 in compensatory damages plus $50,000 in punitive damages.
On September 28, 2015, the district court awarded $25,533.90 in attorney fees in addition to $692.70 in costs previously awarded; the fees were ordered deducted from the judgment awarded by the jury, reducing Lee’s total award to $99,466.10. The defendants appealed the attorney fee award but later voluntarily dismissed their appeal. See: Lee v. Shepler, U.S.D.C. (C.D. Ill.), Case No. 4:11-cv-04064-SLD.
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Related legal case
Lee v. Shepler
|U.S.D.C. (C.D. Ill.), Case No. 4:11-cv-04064-SLD