Makdessi v. Fields, No. 13-7606 (4th Cir. 2015)
Annotate this CasePlaintiff, a former inmate in the Virginia Department of Corrections facilities, filed numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in the facilities. Plaintiff brought suit against various prison officials alleging violations of his right under the Eighth Amendment to be free from cruel and unusual punishment. The magistrate judge found that Defendants should have been more diligent in handling Plaintiff’s complaints but recommended that because Defendants did not actually know of the substantial risk of harm Plaintiff faced, his claims failed. The district court adopted in its entirety the findings and recommendation of the magistrate judge. The Fourth Circuit vacated the dismissal of Plaintiff’s claims against certain defendants, holding that the magistrate judge and district court failed to appreciate that the subjective “actual knowledge” standard required to find prison officials deliberately indifferent to a substantial risk of serious injury may be proven by circumstantial evidence that a risk was so obvious that it had to have been known. Remanded.
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