United States Fourth Circuit

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Makdessi v. Lt. Fields, 13-7606

In this prisoner civil rights case, plaintiff lodged numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in Virginia Department of Corrections facilities. The magistrate judge recommended, and the district court adopted, the view that because the prison officials named as defendants in this suit did not actually know of the substantial risk of harm plaintiff faced, his claims must fail. The dismissal of plaintiff's claims is vacated and the matter is remanded for reconsideration, where: 1) the subjective "actual knowledge" standard required to find prison officials deliberately indifferent to a substantial risk of injury may be proven by circumstantial evidence; 2) prison officials may be held accountable when a risk is so obvious that it had to have been known; and 3) the district court did not apply this proper legal framework in assessing plaintiff's claims.

Appellate Information

  • Decided 03/12/2015
  • Published 03/12/2015

Judges

  • Wynn

Court

  • United States Fourth Circuit

Counsel