Smith v. Johnson, No. 13-2491 (8th Cir. 2015)
Annotate this CaseSmith, labeled as a “snitch,” was attacked by other inmates in the Varner Unit of the Arkansas Department of Correction. He was removed from the Unit and placed in protective custody. Smith alleges that correctional officer Johnson later returned him to the general population in the Varner Unit, without Smith’s consent and in violation of departmental policies. According to Smith, the next day another inmate severely beat him with his fist and a lock, causing scarring, a lost tooth, migraines, blurred vision, sensory losses, dizzy spells, and psychological symptoms. After the attack, Smith claims that Johnson and other officers punished him using “major disciplinary policies.” Smith unsuccessfully pursued grievances and filed a pro se claim with the State Claims Commission. The Commission dismissed Smith’s claim for failure to prove any negligence by the Department of Correction. Smith next filed suit under 42 U.S.C. 1983, alleging “deliberate indifference for [his] safety” and cruel and unusual punishment. The district court dismissed, ruling if the Claims Commission had jurisdiction over Smith’s constitutional claim, the action was barred by claim preclusion; if the Commission did not have jurisdiction over that claim, issue preclusion barred Smith’s claim. The Eighth Circuit reversed, finding that neither doctrine barred the suit.
Court Description: Prisoner case - Prisoner civil rights.In action alleging two prison officers were deliberately indifferent to plaintiff' safety by placing where another inmate could attack him and then intentionally disciplining him for the incident, the district court erred in finding that the suit was barred by either the doctrine of claim preclusion or issue preclusion in light of a prior decision by he Arkansas State Claims Commission on a claim by plaintiff; with respect to claim preclusion, that doctrine does not apply because the Commission was the only forum in which he could bring his claim against the State, but the Commission did not have jurisdiction to address a constitutional claim against Officer Johnson individually; with respect to issue preclusion, the Commission did not decide the issue plaintiff Smith seeks to litigate in the current issue - whether Johnson individually was deliberately indifferent to his safety and intentionally cruelly and unususally punished him for the altercation in violation of the Eighth Amendment - because the Commission's determination dealt with whether Johnson acted negligently; reversed and remanded for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.