Beal v. Foster

Ronald Beal (plaintiff) was an inmate at a Wisconsin state prison. Beal filed a complaint against prison warden Brian Foster and prison guard Russell Schneider (defendants) under 42 U.S.C. § 1983, claiming that Schneider had subjected Beal to cruel and unusual punishment violating the Eighth Amendment. Specifically, Beal’s complaint alleged that (1) Schneider had made verbal comments telling Beal to place his penis inside Brian Anthony, another inmate, and (2) Schneider had on multiple occasions urinated in front of the plaintiff and other inmates while looking at them and smiling. Beal claimed that Schneider’s actions caused Beal to suffer severe psychological harm for which he sought help from the prison’s clinic. Federal law required screening of prisoner complaints against government entities to determine whether the claims were legally viable. During that screening process, a district court dismissed Beal’s complaint, concluding that Beal’s claim was not viable because it alleged only verbal harassment and verbal harassment of a prisoner, by itself, did not constitute a constitutional violation. Beal appealed. In his appellate filings, Beal provided additional facts, claiming that Schneider had told another inmate, in front of Beal and others, that Beal should place his penis in the other inmate’s mouth to make him smile. Beal also stated that other inmates harassed him using derogatory terms for homosexuals. The court of appeals considered whether the district court’s dismissal was proper.