Steven Keith Jones v. Alabama Department of Corrections, et al.

Summary

The United States District Court for the Northern District of Alabama overruled Steven Keith Jones’s objections to the Magistrate Judge’s Report and Recommendation. The court adopted the Report and Recommendation, construed Defendants’ special report as a motion for summary judgment, and granted summary judgment to the defendants. The court concluded that Jones had not properly presented or sought discovery concerning additional allegations and that his deliberate-indifference theory against Officer Chevelle Hunte failed on the merits.

Holdings

1. Plaintiff's objection that he had no right or opportunity to request discovery was unfounded because the special-report order expressly allowed him to seek leave to conduct additional discovery, and he did not do so.
2. Plaintiff could not avoid summary judgment by asserting for the first time in his late reply additional factual allegations and theories that he had not included in the complaint or identified in response to the special-report order.
3. An assertion that Officer Hunte had authority to notify a shift commander of inadequate security did not establish the subjective awareness required for deliberate indifference; a defendant's failure to perceive a risk that she should have perceived does not, without more, constitute a constitutional violation.

Questions Presented

1. Whether the court properly construed defendants' special report as a motion for summary judgment.
2. Whether plaintiff was denied an opportunity to request discovery before summary judgment was considered.
3. Whether plaintiff's deliberate-indifference theory against Officer Hunte could survive summary judgment based on alleged authority to notify a supervisor of unsafe conditions.

Disposition

other