Rutledge v. Springborn, U.S. District Court, 1993.

Position:Legal Briefs

In this Illinois case, a U.S. District Court ordered that a trial take place to decide whether prison officials were deliberately indifferent to an inmate's safety and circumstances. A 27-year-old inmate, Steve Rutledge, was serving a 70-year sentence for murder at Joliet Correctional Center. He was known to be an effective jailhouse lawyer and consequently, he claimed, was poorly treated by prison officials.

In June 1990 Rutledge learned of an attempted escape by some other inmates. He eventually told prison officials about the escape attempt and gave them the names of specific inmates involved in it. Afterward, Rutledge wasconcemed for his safety as a result of his having snitched. Despite assurances of confidentiality from prison officials, Rutledge claimed that he received threats from other inmates and was burned twice by having hot liquid thrown on him. Rutledge sued, claiming his Eighth Amendment rights had been violated.

In deciding this case, the court determined that Rutledge would have to show that prison officials intentionally failed to protect him from other inmates. It wrote, "Because the Eighth Amendment does not impose absolute liability, Rutledge must raise a reasonable inference that the prison officials acted with intent. It is not enough to show negligence or even recklessness." The court held that Rutledge raised this inference. Since Rutledge was put back into the same unit after his confidentiality was compromised, he could show that prison officials were deliberately indifferent to the consequences beforehand.

Tittle v. Jefferson County Commission, U.S. Court of Appeals, 1994

In this Alabama case, a U.S. Court of Appeals upheld a lower court's decision that jail officials did not display deliberate indifference to the mental condition of two inmates who committed suicide. Stephen Tittle and Tomis Harrel, in two separate incidents, hanged themselves in the Jefferson County Jail. In...

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