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Eighth Circuit Affirms Dismissal of Minnesota Prison Workplace Injury Lawsuit

by Lonnie Burton

On February 2, 2017, the U.S. Court of Appeals for the Eighth Circuit affirmed the ruling of a federal district court in Minneapolis which dismissed a lawsuit filed by a prisoner who lost three fingers in an on-the-job accident. The appellate court found that the lower court properly determined that mere negligence by prison officials is insufficient to sustain a claim of cruel and unusual punishment under the Eighth Amendment.

In 2013, prisoner Steven Kulkay was incarcerated at the Fairhurst, Minnesota, correctional facility. He was put to work in the prison's industrial workshop and assigned to the beam saw, a large machine that uses computers to automatically move and cut wood beams. The beam saw in the Fairhurst workshop was designed to use plastic safety guards to protect the operator from the blades. According to the complaint later filed by Kulkay, Fairhurst officials never installed the safety guards and they sat unused in a workshop closet.

After about two-and-a-half months on the job, Kulkay still had not received any safety training from prison officials, the lawsuit said. On August 5, 2013, Kulkay severed three of his fingers and part of a fourth while operating the saw. Doctors were unable to reattach the fingers.

Kulkay then brought a 42 U.S.C. § 1983 action against several Fairhurst officials and the State of Minnesota for violating his civil rights under the Eighth and Fourteenth Amendments. Kulkay also brought negligence complaints against the prison based on vicarious liability. All of Kblkay's claims were dismissed on summary judgment on both qualified immunity grounds and for failing to state a claim upon which relief can be granted. Kulkay appealed, but only the dismissal of his Eighth Amendment claims.

In affirming the district court's dismissal of the case, the Eighth Circuit held that Kulkay's claims were barred because, based on the facts as alleged in the complaint, the defendants were entitled to qualified immunity "insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known."

The court found that while Eighth Amendment protections do extend to conditions of incarceration and confinement, including prison work assignments, a prisoner must show that the prison official acted with a "sufficiently culpable state of mind" to prevail. In other words, absent a showing of "deliberate indifference to inmate health or safety," a prison official is not liable for work injuries suffered by a prisoner under the Eighth Amendment.

"Kulkay has not alleged facts which show that Fairhurst officials were deliberately indifferent" to the risk of injury commensurate with the failure to install the safety guards and not providing formal safety training to Kulkay, the court said. "Deliberate indifference requires a highly culpable state of mind," the court ruled, one “approaching actual intent.”

Because Kulkay did not allege facts sufficient to show that Fairhurst officials had actual knowledge of the alleged dangerous conditions in the workshop and that they willfully overlooked those dangers, Kulkay's claims did not rise to the level of deliberate indifference and thus the lawsuit was properly dismissed by the district court on qualified immunity and failure to state a claim grounds, the court concluded.

Finally, the Eighth Circuit rejected Kulkay's request to remand the case to allow him to conduct discovery to prove a deliberate indifference claim. "Because Kulkay fails to state a claim of violation of clearly established law, he is not entitled to discovery before dismissal." See: Kulkay v. Roy, No. 16-1801 (8th Cir. 2017).

Related legal case

Kulkay v. Roy


 

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