Eleventh Circuit Affirms Dismissal of Prison Death Lawsuit, Rules Officials Lacked 'Subjective Knowledge' of Gang Threat

The case centers on the August 2021 death of Jamari McClinton, an inmate who was killed at Baldwin State Prison just days after being transferred there from Phillips State Prison. McClinton had stabbed a high-ranking member of the Bloods gang while at Phillips, prompting officials to place him in protective custody and arrange his transfer. However, upon arrival at Baldwin, McClinton was housed in general population where another Bloods member stabbed him to death on August 11, 2021.

Writing for a unanimous panel, Circuit Judge Branch affirmed summary judgment for the five officials, holding that none possessed the requisite subjective knowledge of harm to McClinton. The court applied the Eleventh Circuit's recent en banc decision in Wade v. McDade to reject the family's claims under the Eighth Amendment's prohibition on cruel and unusual punishment.

The appeals court systematically rejected the family's arguments against each defendant. For Phillips State Prison Warden James Perry, who had placed McClinton in protective custody, the court held he "responded reasonably to that known risk by placing McClinton in protective custody and seeking a transfer." For classification analyst Eladio Abreu, who approved the transfer, the family "conceded that Abreu had no knowledge that transferring McClinton to Baldwin would cause any risk of harm."

Baldwin State Prison Warden Walter Berry and counselor Jarvis Primus were held to have "no knowledge of McClinton at all, let alone of any substantial risk he faced." The court's analysis of Lieutenant Nolita Moss was most detailed, as she was the only official who had direct contact with McClinton about safety concerns at Baldwin. McClinton had told Moss he wanted protective custody but then withdrew his request and asked to return to his dormitory.

The family had sued the five officials alleging each violated the Eighth Amendment by being deliberately indifferent to the risk McClinton faced at Baldwin. The case reached the Eleventh Circuit after U.S. District Judge Marc T. Treadwell in the Middle District of Georgia granted summary judgment for all defendants.