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Garrett v. United States
United States District Court for the Northern District of Georgia
501 F. Supp. 337 (1980)
Steve Rollins was originally incarcerated for second-degree murder in a Rhode Island state prison. However, he was transferred to the Atlanta Federal Penitentiary because the state facilities could not handle his behavior. Rollins’s prison file disclosed that although unprovoked, he assaulted correctional officers three separate times, assaulted another inmate, murdered another inmate, and committed many other offenses. However, his file did not contain any psychological evaluations. Rollins was initially placed in segregation for nine days upon arriving at the federal prison. He was then placed in the A cellhouse, a large area that housed 500 to 600 prisoners in multitiered cells. Two or more inmates shared cells in the A cellhouse, and inmates could mix with each other in the common areas and in individual cells. John Garrett (plaintiff) was an also inmate in the A cellhouse and a slight acquaintance of Rollins. One afternoon, Rollins offered to share a joint of marijuana with Garrett. When Garrett declined, Rollins stabbed him twice in the back with a steel building rod. One of Garrett’s lungs was punctured and partially collapsed. Garrett then sued the United States (defendant) for damages under the Federal Tort Claims Act. The government argued that it observed Rollins in segregation for nine days after he first arrived, and that it decided he did not require special housing arrangements. The government also argued that it could not have reasonably anticipated that Rollins would attack a fellow inmate, because it cannot predict human behavior.
Rule of Law
Holding and Reasoning (Evans, J.)
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