Rodriguez v. Secretary for Department of Corrections

Miguel Rodriguez (plaintiff) filed suit under 42 U.S.C. § 1983 against prison officials Raymond Kugler and Charles Johnson (defendants), claiming that they violated his Eighth Amendment right to be free from cruel and unusual punishment by failing to protect him from other inmates. Rodriguez disclaimed membership with a prison gang, the Latin Kings. Thereafter, he began receiving death threats from its members. He told prison officials of the threats on his life and was placed on close management, separating him from the general prison population. However, after a time, a classification review meeting was held, and prison officials determined that Rodriguez should return to the general population despite Rodriguez filing a request form to remain segregated and relaying to Kugler and Johnson separately that he learned of more threats against his life. Within hours of returning to the general population, Rodriguez was stabbed and severely beaten by members of the Latin Kings. He brought suit. Before the trial, the district court granted summary judgment in favor of Kugler. The claims against Johnson went to trial; however, after Rodriguez’s case-in-chief, the district court granted judgment as a matter of law in favor of Johnson based on its finding that Johnson’s conduct did not cause an Eighth Amendment violation because he did not have final authority over Rodriguez’s release to general population. Rodriguez appealed.