Walker v. Fischer

Summary

The Second Circuit affirmed summary judgment for prison officials in Tyrone Walker’s 42 U.S.C. § 1983 action. The court rejected his due process challenge to physical restraints in restrictive housing, declined to consider his equal protection argument because it was raised for the first time on appeal, and held that restricting supportive medical boots did not constitute deliberate indifference to medical needs.

Holdings

1. The restraint procedures afforded Walker due process because he received written reasons for each restraint order and an opportunity to object, and the procedures were adequate in light of the prison-safety concerns presented.
2. The court would not consider Walker's equal protection argument concerning an allegedly similarly situated inmate because Walker had not presented that comparator argument to the district court.
3. Denying Walker supportive medical boots inside his cell did not violate the Eighth Amendment where medical and security personnel reasonably balanced his medical needs against the risk that the boots could be used as a weapon.

Questions Presented

1. Whether the use of physical restraints on Walker in the Special Housing Unit violated due process.
2. Whether Walker's equal protection claim based on the use of restraints against him but not against an allegedly similarly situated inmate could be considered when the comparator argument was raised for the first time on appeal.
3. Whether denying Walker supportive medical boots inside his cell, based on prison-security concerns, constituted deliberate indifference to serious medical needs in violation of the Eighth Amendment.

Disposition

affirmed