Axelson v. Watson, No. 19-3591 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's sua sponte grant of judgment as a matter of law to defendants in an action brought by plaintiff against prison officials, alleging that they failed to protect him from his fellow inmates after he was labeled a snitch.
Even assuming the court agreed with plaintiff that Federal Rule of Civil Procedure 50(a) requires a motion, the court did not think that requirement is clear or obvious under its case law. The court concluded that the district court did not err in directing a verdict in favor of the five defendants who were not on the Classification Committee. In this case, plaintiff cannot show that defendants acted with deliberate indifference by entrusting the decision to the Classification Committee—the prison's selected arbitrator. The court explained that, even if they disagreed with the choice, there is nothing to suggest that four of the defendants had any power to circumvent the ruling of the Classification Committee and it was a close call with the fifth defendant. Finally, the court concluded that the district court did not abuse its discretion by denying plaintiff's motions for continuance by ensuring an expeditious disposition of the case and while affording significant time to allow plaintiff to prepare.
Court Description: [Kobes, Author, with Kelly and Grasz, Circuit Judges] Civil Case - Civil Rights. In claims of failure to protect from harm, district court did not err in sua sponte granting judgment as a matter of law to five defendants, as court did not plainly err in ruling sua sponte and did not err in dismissing defendants not part of the committee who decided Axelson's placement or the Warden. The district court did not abuse its discretion in denying a continuance of the jury trial against two other defendants.
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