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Fourth Circuit Vindicates Inmate’s Right To Safety And Access To Justice

On January 11, 2010, the United States Court of Appeals for the Fourth Circuit rendered an opinion in Brown v. N.C. D.O.C., No. 08-8501 (4th Cir.) affirming an inmate’s basic right to safety while incarcerated and the importance of an inmate’s right to petition the courts for relief when institutional health and safety violations warrant such relief. The PJC has represented Mr. Samuel Brown, a prisoner in North Carolina who filed a pro se complaint against three prison guards alleging that the guards knew that another inmate posed a serious threat to Mr. Brown’s safety, and yet knowingly did nothing to prevent the ensuing assault.  One of the guards even watched the assault but did not intervene as Mr. Brown was viciously beaten.  A steel plate had to be placed in Mr. Brown’s jaw after the assault, and he continues to receive medical treatment.  Pursuant to the Prison Litigation Reform Act (PLRA), the district court dismissed Mr. Brown’s complaint shortly after it was filed, without even waiting for an answer from the defendants.  Former Francis D. Murnaghan Appellate Advocacy Fellow Matthew Hill was retained by Mr. Brown and filed a brief on his behalf.  The brief argued that federal courts have a duty to liberally construe pro se civil rights complaints in order to protect the access to justice of individuals living in poverty.  Pro se complaints should be evaluated by whether their factual allegations set forth any claim for relief, not whether the complainant uses the correct legal phrasing, and, significantly, the PLRA, which has denied prisoners open access to courts in many other ways, does nothing to change this important rule. Because Mr. Brown alleged sufficient facts from which a reasonable person could infer that each of the guards ignored the serious risk of substantial harm to him from the aggressor inmate, his complaint stated a claim for relief under the 8th Amendment.  Matthew Hill presented oral argument to the Court on October 30, 2009.  Immediately after argument, Judge M. Blane Michael acknowledged from the bench the importance of pro bono work by the Francis D. Murnaghan Appellate Advocacy Fellow and thanked Mr. Hill for his service.

In its recent opinion, the Court adopted much of the legal argument advanced by the Public Justice Center and reversed the decision of the lower court to dismiss Mr. Brown’s complaint.  While the decision is a complete victory for Mr. Brown, it is not a published opinion by the Court, and thus its precedential value for future cases is limited.  The Public Justice Center intends to request that the Court publish its decision.

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