Brooks v. Warden, No. 13-14437 (11th Cir. 2015)
Annotate this CasePlaintiff, currently incarcerated in the Special Management Unit (SMU) at Georgia Diagnostic and Classification Prison (GDCP), filed suit alleging claims stemming from injuries he sustained during a prison riot and from the conditions of his confinement at the hospital after the riot. The court affirmed the dismissal of plaintiff's failure to protect claim arising out of the prison riot because plaintiff did not adequately allege a substantial risk of serious harm in the period leading up the prison riot. However, the court concluded that plaintiff did adequately plead an Eighth Amendment violation arising out of his three-day hospital stay. Moreover, as to the claim that plaintiff had been confined in conditions lacking in basic sanitation, Deputy Warden Powell is not entitled to qualified immunity. The Deputy was put on fair notice both by the court's caselaw and the knowledge that forcing a prisoner to soil himself over a two-day period while chained in a hospital bed creates an obvious health risk and is an affront to human dignity. The court further concluded that plaintiff cannot recover compensatory or punitive damages because he has not alleged any physical injury resulting from his hospital stay, under the Prison Litigation Reform Act, 42 U.S.C. 1997e(e). However, plaintiff can proceed with his claim for nominal damages for a violation of his Eighth Amendment rights. Accordingly, the court affirmed in part, reversed in part, and remanded.
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