Prisons – Correctional officials granted immunity in lawsuit over inmate’s murder

Where two prison officials let two inmates out of their cells, and one inmate then murdered another inmate, the officials were entitled to qualified immunity. The record did not show that they were deliberately indifferent.

Background

After a South Carolina Department of Corrections officer let inmates Jonathon Dominick and Dashaun Simmons out of their cells, Dominick retrieved a homemade weapon and brutally murdered Simmons. Simmons’s estate sued several prison officials, alleging that they violated the Eighth Amendment by being deliberately indifferent to Simmons’s safety and medical needs. The district court granted summary judgment for the officers on qualified immunity grounds.

Standard

Since Jackson sued the officers in their individual capacities, they’re protected by qualified immunity so long “as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” To overcome this defense, Jackson must show “(1) that the government official[s] violated a statutory or constitutional right and (2) that right was clearly established at the time of the challenged conduct.”

Deliberate indifference

Jackson claims that Gerald Bush and Michelle Mapp were deliberately indifferent to Simmons’s risk of being attacked. At oral argument, Jackson conceded that his claim against Mapp might not rise to the level of deliberate indifference. This court agrees.

Since Mapp was only a trainee, not a certified officer, she couldn’t handle keys or open any doors in the facility herself. She believed that Bush had verified that Dominick and Ransom could be released before he opened their cells. And Mapp also wasn’t aware that Simmons was being threatened by other inmates at McCormick, that he’d been attacked at other facilities or that Dominick had a weapon. So there’s no evidence that Mapp knew that Simmons faced a substantial risk of harm.
Jackson nevertheless argues that Bush disregarded an obvious risk to Simmons’s safety by failing to properly verify that Dominick and Ransom were allowed out of their cells and by failing to closely supervise the inmates. In hindsight, letting Dominick and Ransom out posed a significant threat. But the court must consider how Bush perceived the risk at the time. And the record doesn’t show that he subjectively perceived a risk when he let the two inmates out.

Jackson next claims that Cheryl Youngquist and Dontai Parks were deliberately indifferent to Simmons’s medical needs after he was stabbed. At oral argument, Jackson conceded that he may not have a viable claim against Parks. This court agrees that Parks, who drove Simmons to first responders on his golf cart, wasn’t deliberately indifferent to Simmons’s medical needs.

As to Youngquist, Jackson argues that Youngquist was deliberately indifferent to Simmons’s medical needs because when another inmate called for help after the attack, she initially “thought they were playing” and didn’t open the dorm’s entrance door immediately. The magistrate judge found that “nothing in the record showed that Youngquist’s . . . actions were grossly incompetent” or otherwise rose to the level of deliberate indifference. The judge concluded that Youngquist instead “acted to assist Simmons immediately upon [her] realization of his serious medical need.” J.A. 2386.
Jackson objected to these findings, but he didn’t offer any argument or evidence as to why the magistrate judge was wrong.

So the district court found his objections conclusory and overruled them. The lack of specificity in Jackson’s objections means that he has forfeited them on appeal. And on the merits, the deliberate indifference claim still fails; there’s no evidence that Youngquist knew that Simmons needed medical attention when she arrived at the dorm.

Finally, Jackson brought a supervisory liability claim against Thomas Robertson, the associate warden. But at oral argument, he also conceded this claim. This court agrees with the district court that Jackson failed to show “that Robertson had actual or constructive knowledge that Bush was engaged in conduct that posed a pervasive and unreasonable risk of constitutional injury to inmates.”

Affirmed.

Concurring/dissenting opinion

Gregory, J., concurring in part and dissenting in part: Three weeks before Simmons’s death, he asked prison staff if it was “necessary for someone to die before someone will take him seriously.” And now, even after Simmons’s death, his haunting question is left unanswered. Simmons is not here to flesh out the record before us, to tell us what happened and who was responsible.

As we attempt to understand the events leading to his death, we must view the record in the light most favorable to the nonmovant. The majority instead fully credits the account of the moving party—Bush—and dismisses any inferences that may be made against him. I believe this is error, so I would reverse the district court’s decision as to Bush.

Jackson v. Bush, Case No. 25-1449, July 9, 2026. 4th Cir. (Diaz), from DSC at Aiken (Austin). Joshua Thomas Hawkins for Appellant. Andrew Lindemann for Appellees. VLW 026-255. 29 pp.

Full-Text Opinion.