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Fourth Circuit Publishes Opinion Reinforcing Importance of Inmate’s Right to Safety and Access to Justice

On July 20, 20100, the United States Court of Appeals published its previously unpublished opinion in Brown v. N.C. D.O.C., No. 08-8501 (4th Cir.), affirming a prison inmate’s basic right to safety and the importance of an inmate’s right to petition the courts for relief from health and safety violations. In the case, Mr. Samuel Brown, a prisoner in North Carolina had filed a complaint on his own against three prison guards alleging that the guards knew that another inmate posed a serious threat to Mr. Brown’s safety, and yet did nothing to prevent the ensuing assault. The complaint alleged that one of the guards even watched the assault but did not intervene as Mr. Brown was viciously beaten. Pursuant to the Prison Litigation Reform Act (PLRA), the district court dismissed Mr. Brown’s complaint shortly after it was filed.


Former Francis D. Murnaghan Appellate Advocacy Fellow Matthew Hill was retained by Mr. Brown for the appeal and argued that the court should evaluate prisoner complaints by whether their factual allegations outline a serious threat to health or safety ignored by prison officials, not whether the complaint uses the correct legal phrasing. Additionally, the brief highlighted the ways in which the PLRA has denied prisoners open access to courts, allowing for quick dismissals of inmate complaints. On January 11, 2010, the Court issued an unpublished opinion reversing the district court’s decision and reinstating Mr. Brown’s claim. The Public Justice Center requested that the Court publish its opinion, and the Court granted that request on July 20, 2010. Publication of this opinion is significant because district courts throughout the Fourth Circuit must now follow the guidelines given in the Brown opinion when deciding whether to dismiss a prison inmate’s complaint about serious threats to life, health or safety. Very few published opinions are issued on this subject in part because so few inmates are represented by an attorney on appeal. The PJC and Murnaghan Fellowship Committee hope that this decision will result in improved health and safety and access to justice for all prison inmates.

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