JEFFERSON CITY – The U.S. Court of Appeals for the Eighth Circuit has reversed a lower court decision and granted qualified immunity to a State Department of Corrections supervisor accused of violating an inmate’s constitutional rights, siding with Attorney General Andrew Bailey’s office in a ruling that reaffirms the high standard for proving deliberate indifference under the Eighth Amendment.
Bailey
The case stemmed from an incident in which inmate Jeffrey Joseph injured his thumb while operating a press-brake machine in a prison metal plant.
The machine, designed to bend and punch holes in metal, was equipped with hand restraints to help prevent injuries. Although the restraints were available to Joseph, he did not use them on the day of the injury.
Joseph alleged that his supervisor, Kurt Schmiedeskamp, discouraged use of the restraints, telling him, “Oh we don’t use them because they slow production, just don’t get your hand caught in there and we will all be ok.”
Joseph filed suit claiming Schmiedeskamp’s conduct amounted to cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments.
He argued that Schmiedeskamp acted with deliberate indifference to his health and safety by failing to enforce the use of the restraints. The district court denied Schmiedeskamp’s motion for summary judgment, concluding that qualified immunity did not apply, prompting the interlocutory appeal.
Writing for the appellate panel, Circuit Judge Morris Sheppard Arnold explained that to prevail on his claim, Joseph had to show that Schmiedeskamp acted with a highly culpable state of mind “approaching actual intent” to harm him, not mere negligence or gross negligence.
The court noted that constitutional liability under the Eighth Amendment requires proof of criminal recklessness and that even if a violation is proven, a plaintiff must also demonstrate that the law was clearly established at the time of the conduct.
The district court had relied on the 2007 case, Ambrose vs. Young, where an officer ordered inmates into an obviously dangerous situation involving a dangling power line, resulting in an inmate’s death.
But the appellate court found the case distinguishable, noting that Schmiedeskamp’s comments did not demonstrate awareness of a substantial risk comparable to that in that case. Evidence in the record even suggested Schmiedeskamp believed the restraints carried risks of their own, and there was no indication the press-brake machine had caused prior injuries.
Instead, the panel pointed to a line of Eighth Circuit precedents where inmates suffered industrial or construction-related injuries but courts found no constitutional violation because the officials’ conduct amounted to, at most, negligence.
Applying those rulings, the court concluded that Schmiedeskamp’s alleged failure to require use of the restraints did not meet the constitutional threshold for cruel and unusual punishment.
Safety equipment was available, Joseph had been trained to operate the machine, and there was no history of similar injuries.
The Eighth Circuit emphasized that “not every deviation from ideally safe conditions constitutes a violation of the constitution” and that the Eighth Amendment does not transform workplace safety regulations into constitutional mandates.
Even if Schmiedeskamp’s conduct were assumed to be a constitutional violation, the court found that Joseph had not shown it violated clearly established law.
The appellate decision held that existing precedent did not clearly establish that a supervisor’s awareness of potential safety concerns — without more — amounts to deliberate indifference under the Eighth Amendment.
The ruling reversed the district court’s denial of summary judgment and remanded the case, shielding Schmiedeskamp from liability under the doctrine of qualified immunity.
Bailey hailed the opinion as a decisive win for the rule of law and a reaffirmation that negligence alone does not create constitutional liability for public officials acting in good faith.
