Lakin v. Barnhart, No. 13-2210 (1st Cir. 2014)Annotate this Case
The Maine State Prison has a longstanding practice of issuing footlockers with padlocks to most inmates. Appellants, inmates in the Prison, were each seriously injured in assaults by other inmates who used prison-issued padlocks as weapons. Appellants filed complaints in federal district court alleging that the failure of Appellees, officials in the Maine Department of Corrections, to take adequate measures to protect inmates from padlock assaults violated Appellants’ Eighth Amendment rights. The district court dismissed the complaints on summary judgment, concluding that there existed no genuine dispute of material fact as to whether providing inmates with padlocks subjected Appellants to conditions posing a substantial risk of serious harm in violation of the Eighth Amendment. The First Circuit affirmed, holding that the small number of assaults involving the use of prison-issued padlocks, without more, was not sufficient to sustain the conclusion that providing the padlocks to inmates rose to the level of constitutional violation.