King v. Riley

Summary

The Fourth Circuit affirmed summary judgment for prison officials on an Eighth Amendment deliberate-indifference claim arising from an inmate's murder by fellow inmates in a mental health unit. The court held that the defendant officer was entitled to qualified immunity on the failure-to-protect claim because there was no clearly established right to have a correctional officer look into a cell during security checks. Similarly, officers who called for medical personnel but did not personally render aid did not violate a clearly established right. The supervisory-liability claim failed because the plaintiff did not allege or produce evidence of each individual defendant's personal involvement or culpable state of mind.

Holdings

1. Sergeant McKan is entitled to qualified immunity because there was no clearly established constitutional right to have a correctional officer look into the cell window while conducting a security check, given a known and substantial risk of inmate-on-inmate violence.
2. Sergeant McKan and Officer Jones are entitled to qualified immunity because there was no clearly established right that calling for medical personnel without rendering aid themselves violates the Eighth Amendment.
3. King failed to allege or produce evidence of any individual involvement by the supervisory defendants, so the claim fails.

Questions Presented

1. Whether Sergeant McKan was deliberately indifferent to King's safety by failing to conduct proper security checks, and whether he is entitled to qualified immunity.
2. Whether Sergeant McKan and Officer Jones were deliberately indifferent to King's medical needs by calling for medical personnel but not rendering aid themselves, and whether they are entitled to qualified immunity.
3. Whether supervisory defendants (Warden Riley, Associate Wardens Thompson and Lane, Major Jackson) are liable under a theory of supervisory liability for deliberate indifference.

Disposition

affirmed