A former juvenile offender has reached a $3 million settlement with Georgia state officials in a Section 1983 Civil Rights lawsuit brought after an alleged assault at a detention facility.
On July 9, 2011, 16-year-old R.N. was six months away from release at the Eastman Youth Development Campus, where he was serving a three-year sentence for carjacking. He was brutally attacked by a fellow inmate, a violent offender, who shared his cellblock. As a result of the attack, R.N. sustained severe injury including brain damage. His attacker was charged with assault and sentenced to ten years in adult prison.
At the time of the attack, only one officer was on duty, despite a requirement of three. The officer was watching over 32 juveniles, a mix of violent and non-violent offenders. According to the complaint, officials made a series of serious missteps leading up to the incident, including keeping the assailant in the general population after he had physically and sexually assaulted two other inmates.
R.N.’s claims against state officials—employees and directors with the Department of Juvenile Justice—alleged violations of his rights under the Eighth and Fourteenth Amendments to the U.S. Constitution and were brought pursuant to 42 U.S.C. § 1983.
Section 1983 is a powerful tool for citizens to seek relief when their civil rights have been violated. In many cases, state and local officials are immune from suit under state laws. In this case, however, R.N. alleged that the defendants failed to take reasonable measures to protect him from a known violent fellow inmate and therefore subjected him to a substantial risk of serious harm. He claimed their actions exhibited “deliberate indifference” to his safety and subjected him to “unnecessary and wanton infliction of pain and violence constituting cruel and unusual punishment,” a violation of the Eighth and Fourteenth Amendments.
According to records, juvenile justice officials had discussed concerns about the assailant just days before he attacked R.N. On July 3, 2011, the two inmates were involved in a physical altercation but were put back on the same cellblock. Then on July 9, the assailant and three others attacked the officer on duty before turning on R.N. and beating him unconscious. He was in a “vegetative state” for seven weeks.
This was an outstanding result for R.N., and a great job by his lawyers. Section 1983 lawsuits allow victims like R.N. to obtain compensation for harm caused when the system does not adequately otherwise protect their rights. They also put pressure on state officials to improve the system to prevent future incidents. Hopefully, this settlement will help improve conditions at youth detention facilities across Georgia.
Page Pate is an accomplished trial lawyer with over 25 years of experience in criminal defense, civil litigation, and whistleblower representation. Page is listed in The Best Lawyers in America, Top 100 Lawyers by The National Trial Lawyers, and named to the list of Super Lawyers for the past 15 consecutive years. Page is a frequent expert legal analyst for local and national media and has served as an Adjunct Professor at the University of Georgia Law School. Read Page’s reviews on AVVO. Follow Page on Twitter @pagepate and on Linkedin.