Brown v. Wood

Summary

Richard Brown, a state prisoner, brought a 42 U.S.C. § 1983 action alleging that prison officials were deliberately indifferent to a substantial risk of assault when they released him from protective custody into the general population. The court held that the undisputed facts showed, at most, an error in judgment rather than deliberate indifference under the Eighth Amendment, and affirmed summary judgment for the defendants.

Holdings

1. The undisputed facts could support a finding that the defendants erred in returning Brown to the general population, but they did not constitute evidence of deliberate indifference to a known substantial risk of harm.
2. Summary judgment was reviewed de novo, with ambiguities resolved and factual inferences drawn in favor of the nonmoving party, and the judgment for defendants was affirmed.

Questions Presented

1. Whether the defendants were deliberately indifferent to a known substantial risk of serious harm in returning Brown from protective custody to the general prison population.
2. Whether summary judgment was proper on Brown's Eighth Amendment failure-to-protect claim.

Disposition

affirmed