Robinson v. Lay

CourtDistrict Court, E.D. Arkansas
DecidedMarch 28, 2025
Docket2:22-cv-00106
StatusUnknown

This text of Robinson v. Lay (Robinson v. Lay) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson v. Lay, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION ANTONIO C. ROBINSON VDC #2166073 PLAINTIFF

No. 2:22-cv-106-DPM

GAYLON LAY, Superintendent, East Arkansas Regional Unit; CHRISTOPHER | JOHNSON, Deputy Warden, East Arkansas Regional Unit; and MICHAEL RICHARDSON, Deputy Warden, East Arkansas Regional Unit DEFENDANTS

ORDER An administrative housing cell in the East Arkansas Regional Unit measures 85.5 square feet. It has a concrete bed with a mattress. Some space is taken up by a toilet and a desk. There is a horizontal window, a long rectangle about as wide as a person’s arm. Antonio Robinson lived in one of those cells from September 2021 to August 2022. He was there because another inmate had threatened to kill him. During those eleven months, he was offered one hour of exercise outside his cell only three or four times. Robinson could and did leave for showers a few times a week, plus the occasional trip to the barber or doctor. Otherwise, there he stayed. His cell was within earshot of mental health inmates who would scream, set fires, and intentionally flood their toilets. Robinson says his mental health

deteriorated as a result. He attempted suicide by cutting his wrists. He also says that being forced to lay in his cell with little to no movement caused back problems. Superintendent Lay was Warden of the East Arkansas Regional Unit during that time. Johnson and Richardson were deputy wardens. Robinson has sued all three, claiming that they deprived him of his right to be free from cruel and unusual punishment. Both sides have moved for summary judgment. The Magistrate Judge recommends dismissal. Robinson filed objections, so the Court’s review is de novo. Fed. R. Civ. P. 72(b)(3). A few preliminary matters. Robinson’s official-capacity claims are barred. Kruger v. Nebraska, 820 F.3d 295, 301 (8th Cir. 2016). And his claim for injunctive relief—a transfer out of the East Arkansas Regional Unit—is moot. Smith v. Hundley, 190 F.3d 852, 855 (8th Cir. 1999). He has been transferred to a prison in Virginia. The Court adopts the recommendation that these claims be dismissed. The Court also adopts the recommendation that Robinson’s cross motion for summary judgment be denied. Now, the deep issue. Are Lay, Johnson, and Richardson entitled to qualified immunity on the individual capacity claims? When Robinson was in administrative segregation, it was clearly established that prison officials violate an inmate’s constitutional rights

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when they are deliberately indifferent to the inmate’s need to exercise outside his cell. Wishon v. Gammon, 978 F.2d 446, 448-49 (8th Cir. 1992). Like the Magistrate Judge, Doc. 250 at 13-14, this Court liberally reads Robinson’s claim as one for denial of out-of-cell exercise, not solely outdoor exercise. To defeat qualified immunity, Robinson must show that, viewing the facts in the light most favorable to him, Lay, Johnson, and Richardson violated that right. Saylor v. Nebraska, 812 F.3d 637, 643 (8th Cir. 2016). Specifically, Robinson must show there was a substantial risk of serious harm to him, and each defendant was deliberately indifferent to that risk. Letterman v. Does, 789 F.3d 856, 861 (8th Cir. 2015). To determine whether there was a substantial risk of serious harm, the Court considers: (1) Robinson’s opportunities to be out of his cell; (2) whether he could exercise within his cell; (3) the size of the cell; (4) the duration of confinement; and (5) any injuries suffered or other threats to his health. Wishon, 978 F.2d at 449. Lay, Johnson, and Richardson argue hard that there was no substantial risk, relying on three cases involving Arkansas inmates in this period. But these cases are distinguishable; the risk to Robinson was much more serious. In Barnes v. Byers, the prisoner spent 428 days in punitive isolation. 2022 WL 1540170, at *1 (E.D. Ark. 16 May 2022). That’s a few months longer than Robinson. And Barnes’s cell might have been smaller than Robinson’s. He had 63.54 square feet of unencumbered space.

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Barnes, 2022 WL 1540170 at *14. Robinson had 85.5 square feet, though some of that is taken up by the toilet, desk, and bed. Doc. 160-1 at 131. But Barnes had many, many more opportunities to exercise out of his cell. Compare Barnes, 2022 WL, 1540170 at *13. Most months Barnes had more than four opportunities for out-of-cell exercises. Ibid. Robinson had (at most) four opportunities in the entire eleven months he spent in administrative segregation. The cases are simply not comparable. Lay, Johnson, and Richardson also cite Taylor v. Kerstein, 2024 WL 149548 (E.D. Ark. 12 January 2024). Taylor’s cell was the same size as Robinson’s. Taylor, 2024 WL 149548 at *2. But the similarities largely end there. The relevant period for Taylor was five months. (Taylor was in restricted housing for longer than five months but failed to exhaust his earlier claims. Taylor, 2024 WL 149548 at *1-2.) Robinson was in restricted housing for more than twice as long as Taylor. The longest Taylor went without out-of-cell exercise was 80 days, which. Magistrate Judge Volpe found “disturbing.” Taylor, 2024 WL 149548 at *4. Viewing the facts in the light most favorable to Robinson, he went 172 days without an opportunity to exercise outside his cell, from mid-March 2022 to the end of August 2022. And, perhaps most importantly, the threat to Robinson’s health was much higher than to Taylor’s. He said the lack of exercise “caused him to have headaches, stomach problems, joint pain, weight loss, and a vitamin D deficiency,” but his claims were undercut by his

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undisputed medical records. Ibid. Robinson attempted suicide multiple times. Lay, Johnson, and Richardson’s strongest case is the unpublished per curiam decision in Terry v. Randle, 2023 WL 4132800 (E.D. Ark. 22 June 2023), affd, No. 23-3153, 2024 WL 1598215 (8th Cir. 12 April 2024). The prisoner’s confinement was longer: Terry said he was deprived adequate exercise from January or February 2021 to May 2022." He was only offered out-of-cell exercise fifteen times. Still, fifteen times over fifteen months is more frequent than four times over eleven months. And the alleged harm to Terry was much less serious (vitamin deficiency and anxiety) or was unproven (muscle loss) as compared to Robinson, who tried to harm himself on several occasions. Eleven months is a long time in a small cell. Three or four yard calls, including a 172-day period without any other opportunity for exercise outside a cell, are not frequent enough. Robinson could have exercised some in his cell, though it’s disputed whether there was a risk of resulting discipline for doing so. Compare Doc. 160-3 at 4, with Doc. 160-1 at 37-38. And there was a clear threat to Robinson’s health: he grew so depressed that he tried to kill himself. Doc. 160-1 at 38 & 61. All material things considered, viewing the evidence in the light most

* Terry said that the deprivation began with the COVID-19 lock down in 2020, but Magistrate Judge Kearney found that the right to exercise during an international pandemic was not clearly established. Terry, 2023 WL 4132800 at *5.

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Robinson v. Lay, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-lay-ared-2025.