Williams v. Dunn

CourtDistrict Court, N.D. Alabama
DecidedMarch 17, 2025
Docket4:21-cv-00921
StatusUnknown

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

Bluebook
Williams v. Dunn, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION

MARCELLUS WILLIAMS, ) ) Plaintiff, ) ) v. ) Case No. 4:21-cv-00921-MHH-HNJ ) JEFFERSON DUNN, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Plaintiff Marcellus Williams is an inmate at St. Clair Correctional Facility. After another inmate stabbed Mr. Williams in St. Clair’s restricted housing unit, Mr. Williams sued the Alabama Department of Corrections and St. Clair prison officials. (Doc. 1). Mr. Williams asserts § 1983 claims for excessive inmate violence under the Eighth Amendment, state created danger under the Eighth and Fourteenth Amendments, and failure to intervene. (Doc. 1, pp. 59-62).1 Mr. Williams also

1 As the magistrate judge noted, Mr. Williams bases his excessive inmate violence claim on a generalized risk of inmate-on-inmate violence at St. Clair, not on a failure to protect based on a specific or individualized threat to Mr. Williams’s safety. (Doc. 39, pp. 28-29, n. 10); see also Est. of Owens v. GEO Grp., Inc., 660 Fed. Appx. 763, 769, 771 (11th Cir. 2016) (explaining that § 1983 plaintiffs may bring a failure to protect under two different theories: a “particularized risk claim” where the plaintiff was a “target of a specific threat or danger” of which the prison officials were aware and failed to alleviate the risk; and a “dangerous prisons conditions claim” or generalized risk of inmate violence claim where the plaintiff demonstrates that the prison conditions to which he was subjected “were so dangerous that [the conditions] resulted in cruel and unusual punishment”). asserts claims under Alabama law for outrage and negligence. (Doc. 1, pp. 62-64).2 The defendants have moved to strike or dismiss Mr. Williams’s complaint as an

impermissible shotgun pleading. The defendants also seek dismissal under Rule 12(b)(6) of the Federal Rules of Civil Procedure because the defendants contend that Mr. Williams has failed to state a claim. (Docs. 18, 19, 20, 21).

The magistrate judge entered a report in which he recommended that the Court deny the defendants’ motions to strike and grant in part and deny in part the defendants’ motions to dismiss. (Doc. 39). Mr. Williams and the defendants have filed objections to the report. (Docs. 44, 45, 46, 47, 48).

When a magistrate judge issues a report and recommendation regarding a dispositive motion, a district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. §

636(b)(1)(C). A district judge must “make a de novo determination of those portions of the [magistrate judge’s] report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1); see also FED. R. CIV. P. 72(b)(3) (“The district judge must determine de novo any part of the magistrate judge’s

disposition that has been properly objected to.”). A district court’s obligation to

2 As the magistrate judge noted, Mr. Williams labeled his claim as intentional infliction of emotional distress, (Doc. 1, p. 62), which is the same as a claim for the tort of outrage under Alabama law. (Doc. 39, p. 93, n. 30) (citing Thomas v. Williams, 21 So. 3d 1234, 1237 (Ala. Civ. App. 2008)). “‘make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made,’” 447 U.S. at 673 (quoting

28 U.S.C. § 636(b)(1)), requires a district judge to “‘give fresh consideration to those issues to which specific objection has been made by a party,’” 447 U.S. at 675 (quoting House Report No. 94-1609, p. 3 (1976)). United States v. Raddatz, 447

U.S. 667 (1980) (emphasis in Raddatz). Count I—Excessive Risk of Inmate Violence St. Clair supervisors Bolling, Pickens, Malone, and White object to the magistrate judge’s conclusion that Mr. Williams has sufficiently pleaded an Eighth

Amendment excessive risk of inmate violence claim against them. (Doc. 44, p. 3). In his report, the magistrate judge accurately discussed the law regarding excessive risk of inmate violence and qualified immunity, and no party objects to that

discussion. (See Doc. 39, pp. 26-49; Doc. 44, pp. 3-4; Doc. 45, p. 6; Doc. 47, p. 4).3 The St. Clair supervisors challenge the magistrate judge’s conclusions “as to both

3 After the magistrate judge entered his report and recommendation, the Eleventh Circuit decided Wade v. McDade, 106 F.4th 1251 (11th Cir. 2024). In Wade, the Eleventh Circuit explained that to prove that a prison official violated the Eighth Amendment, a prisoner must establish the prison official’s subjective awareness that his conduct, whether it be action or inaction, “put the plaintiff at substantial risk of serious harm,” with the caveat that “even if the defendant ‘actually knew of a substantial risk to inmate health or safety,’ he ‘cannot be found liable under the Cruel and Unusual Punishments Clause’ if he ‘responded reasonably to the risk.’” Wade, 106 F.4th at 1258, 1262 (quoting Farmer v. Brennan, 511 U.S. 825, 844-45 (1994)). The magistrate judge’s analysis of the law included the deliberate indifference standard set out in Farmer and comports with Wade. (See Doc. 39, pp. 57-60). the history of inmate violence” and the “specific features of St. Clair” that allegedly contribute to excessive inmate violence. (Doc. 44, p. 5; see Doc. 39, p. 54). The

supervisory defendants also object to the magistrate judge’s finding that “‘the rate of inmate assaults at St. Clair reflects a generalized risk of violence’” and that the “‘risk of inmate-on-inmate violence at [St. Clair] was obvious.” (Doc. 44, pp. 5, 14

(quoting Doc. 39, pp. 49, 65)).4 The St. Clair supervisors argue that the magistrate judge should have limited his analysis regarding the excessive risk of violence, special features, and the defendants’ subjective awareness of the excessive risk of violence to the restrictive housing unit where Mr. Williams was housed; they

contend that the magistrate judge erred by considering the alleged risk of violence in St. Clair as a whole. (Doc. 44, pp. 5, 11-12, 14).5 The St. Clair supervisors cite the magistrate judge’s finding that “‘Williams cite[d] only ten specific incidents of

inmate violence’” that occurred in the RHU before the attack on him and argue that the ten incidents of violence in the RHU between May 2015 and December 2018 do not establish that Mr. Williams was vulnerable to an excessive risk of violence or that the excessive risk of violence was obvious. (Doc. 44, pp. 6, 9, 10 (citing Doc.

4 Defendants Bolling, Pickens, Malone, and White also argue that the magistrate judge erred when he relied on the total number of inmate assaults at St. Clair for 2019, a number that included inmate assaults on correctional officers. (Doc. 44, p. 5). Though the magistrate judge included the number of inmate assaults on correctional officers, he also provided statistics of inmate-on-inmate violence. (See Doc. 39, pp. 49-51).

5 As Mr. Williams notes, the St. Clair supervisor defendants did not make this argument in their motion to dismiss. (Doc. 48, p. 5). 39, p. 51)) (italics in Doc. 44). The St. Clair supervisors also argue that Mr. Williams has not pleaded causation sufficiently because he has not alleged facts that

demonstrate an excessive risk of violence in the RHU. (Doc. 44, p. 16).

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Williams v. Dunn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-dunn-alnd-2025.