Walker D. Bowenv.Warden, Baldwin State Prison, et al.
The estate of Terrance Bowen sued Georgia prison officials under section 1983 after Bowen was killed by another inmate. The district court dismissed several claims and granted summary judgment to the officials. The Eleventh Circuit affirmed most of the judgment but reversed as to a deputy warden and an officer. The court held that the record could support a finding that those defendants knew of a substantial risk of serious harm and failed to take reasonable protective measures. Because the evidence, viewed in the estate’s favor, could establish deliberate indifference, the officials were not entitled to qualified immunity at the summary-judgment stage. The court distinguished cases involving generalized prison dangers from a record showing notice of a particular inmate’s violent behavior and a failure to monitor or supervise him. The court remanded the surviving claims for further proceedings and affirmed the judgment in all other respects. The published opinion clarified the evidentiary showing required to overcome qualified immunity in a prisoner-protection case.
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