Vonell Lavell Shaw v. Tonia Rozmarynoski

Summary

The United States District Court for the Eastern District of Wisconsin granted Defendant Tonia Rozmarynoski’s motion for summary judgment in Vonell Lavell Shaw’s 42 U.S.C. § 1983 action. The court held that the evidence, including body-camera video, did not show that Shaw faced an objectively serious risk of self-harm or that Rozmarynoski was deliberately indifferent under the Eighth Amendment.

Holdings

1. A prisoner asserting that a correctional official failed to protect him from self-harm must provide evidence that the official was aware of an objectively serious risk of harm. Shaw failed to create a triable issue because the undisputed video and other evidence showed that his controlled headbanging did not pose a substantial risk of serious harm to his health or safety.
2. Shaw failed to show that Rozmarynoski knowingly or recklessly disregarded a serious risk of harm. Her conduct was a reasonable and professional response because she directed an officer to monitor Shaw, contacted the psychologist, summoned staff, and addressed the situation before restraints were applied.
3. Summary judgment was proper because Shaw lacked evidence sufficient to establish an essential element of his Eighth Amendment claim and no reasonable jury could find in his favor on either deliberate-indifference prong.

Questions Presented

1. Whether Shaw presented evidence that Rozmarynoski was aware of an objectively serious risk of harm to him for purposes of an Eighth Amendment deliberate-indifference claim based on self-harming behavior.
2. Whether Shaw presented evidence that Rozmarynoski knowingly or recklessly disregarded such a risk.
3. Whether summary judgment was appropriate where body-camera video definitively resolved the parties' competing descriptions of the severity and circumstances of Shaw's conduct.

Disposition

dismissed