Raymond Lee Gibbs v. Tricia Pretorius a/k/a Trishia Pretorius, Kayla Hall PREA Coordinator, Carrie Sipich, and Katie McMahon

Summary

The United States District Court for the Southern District of Indiana denied Defendants' motion for summary judgment in Raymond Lee Gibbs's failure-to-protect action. The court held that evidence concerning repeated threats, inadequate protective measures, and Gibbs's eventual stabbing created a triable issue as to deliberate indifference under the Eighth Amendment. The court also denied qualified immunity, concluding that the alleged constitutional violation was clearly established.

Holdings

1. Summary judgment was inappropriate because a reasonable jury could find that Defendants knew Gibbs faced a substantial risk of serious injury and failed to take reasonable measures to abate that risk.
2. Defendants were not entitled to qualified immunity because the evidence, viewed favorably to Gibbs, supported a constitutional violation and the right to protection from a known threat of inmate assault was clearly established.

Questions Presented

1. Whether the evidence created a genuine dispute of material fact as to whether Defendants were deliberately indifferent to a substantial risk of serious harm to Gibbs in violation of the Eighth Amendment.
2. Whether Defendants were entitled to qualified immunity because their conduct did not violate a clearly established constitutional right.

Disposition

other