Kamil T. Brown v. Ms. Haldeman, et al.

Summary

The court grants summary judgment to several defendants in Kamil T. Brown’s § 1983 action arising from his placement on an upper prison tier despite alleged medical restrictions, but denies summary judgment on Brown’s Eighth Amendment claims against Unit Manager Pasquale and Sgt. Rook. The court finds insufficient evidence of personal involvement by Haldeman and Vance, while concluding that genuine disputes remain regarding whether Pasquale and Rook were deliberately indifferent to a substantial risk of harm. The court also grants summary judgment on Brown’s § 1985 conspiracy claims.

Holdings

1. Haldeman and Vance were entitled to summary judgment because the surrounding evidence did not permit a reasonable jury to credit Brown's later assertions that he had complained to them before the fall.
2. Pasquale was not entitled to summary judgment on personal-involvement grounds because the evidence was sufficiently consistent for a reasonable jury to credit Brown's account that Pasquale knew of and participated in the challenged housing decision.
3. Summary judgment was denied to Pasquale and Rook because genuine disputes remained as to whether they knew of and disregarded a substantial risk of serious harm created by placing Brown in an upper-tier cell despite his medical restrictions.
4. Summary judgment was granted to Preston, Nurse Vogt, and Sgt. Vogt based on Brown's concession that he failed to exhaust administrative remedies against them.
5. Summary judgment was granted on Brown's § 1985 conspiracy claims because Brown conceded that the facts did not establish an actionable conspiracy claim.

Questions Presented

1. Whether Haldeman, Pasquale, and Vance had sufficient personal involvement in the alleged unconstitutional cell placement to withstand summary judgment.
2. Whether the evidence created a genuine dispute of material fact regarding deliberate indifference by Pasquale and Rook to a substantial risk of serious harm under the Eighth Amendment.
3. Whether defendants were entitled to summary judgment on the remaining claims based on Brown's concessions regarding exhaustion and the § 1985 conspiracy claim.

Disposition

other