Approving a Prisoner’s Grievances Undercuts Retaliation Claims; Eighteen Days Without a Mattress Is Not “Objectively” Cruel and Unusual in the Eleventh Circuit

Introduction

In Eddie James Moultrie v. G. Edwards (No. 24-12887, 11th Cir., Sept. 11, 2025) (not for publication; non-argument calendar), the Eleventh Circuit affirmed the dismissal of a Florida inmate’s § 1983 suit alleging (1) First Amendment retaliation for filing grievances and (2) cruel and unusual punishment under the Eighth Amendment stemming from the confiscation of his mattress for eighteen days. The panel—Judges Grant, Lagoa, and Wilson—held that the complaint failed to plausibly allege a causal connection between protected speech (prison grievances) and the adverse action (mattress confiscation), and that sleeping without a mattress for eighteen days, while uncomfortable, does not meet the Eighth Amendment’s objective threshold of seriousness.

The dispute arose after Moultrie repeatedly sought better cleaning supplies for his “filthy” cell. Lieutenant Gerald L. Edwards, the dorm supervisor and defendant-appellee, approved Moultrie’s grievances and ordered staff to provide cleaning tools to inmates. When additional grievances followed a toilet flood, Edwards again approved a grievance and directed staff to provide what Moultrie requested. Edwards also ordered an officer to enter and clean Moultrie’s cell. The officer discovered contraband: an extra bed sheet and sugar packets, both prohibited under prison rules. Edwards confiscated Moultrie’s mattress as discipline for the contraband sheet and placed him on “meal management” for two meals due to the sugar packets. Moultrie alleged significant back and hip pain from sleeping on a metal frame for eighteen days and sued, claiming retaliation and an Eighth Amendment violation.

The district court dismissed the retaliation claim for failure to state a claim and dismissed the Eighth Amendment claim on exhaustion grounds. On appeal, the Eleventh Circuit affirmed, concluding the complaint was implausible on retaliation and, independently, that the Eighth Amendment claim failed on the objective prong—without reaching exhaustion.

Summary of the Opinion

• First Amendment: The panel held that although filing grievances is protected speech and mattress confiscation would deter an ordinary person, the complaint did not plausibly allege that Edwards was motivated by retaliatory animus. Two facts defeated causation: Edwards had approved the very grievances about cleanliness that allegedly triggered retaliation, and the mattress was confiscated for a rule violation (contraband) acknowledged by Moultrie; no facts plausibly suggested pretext.
• Eighth Amendment: Applying the “objective” component of the conditions-of-confinement test, the court held that sleeping without a mattress for eighteen days, even if uncomfortable and painful, does not cross the “high bar” of exposing an inmate to a substantial risk of serious harm as understood by contemporary standards of decency. Having resolved the claim on the objective prong, the panel did not address deliberate indifference (the subjective prong) or the district court’s exhaustion ruling.
• Disposition: Affirmed. All pending motions were denied as moot.

Analysis

Precedents Cited and Their Influence

• Pleading standards:
  • Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007): The court reiterated that, even liberally construing pro se pleadings, a complaint must allege facts allowing a reasonable inference of liability, not mere speculation. These cases supplied the plausibility framework used to reject the retaliation allegations.
  • Alba v. Montford, 517 F.3d 1249 (11th Cir. 2008): Pro se filings receive liberal construction but must still satisfy plausibility.
• Retaliation:
  • Smith v. Mosley, 532 F.3d 1270 (11th Cir. 2008): Articulates the three elements of a prisoner’s First Amendment retaliation claim: protected speech, adverse action likely to deter, and causation.
  • Wildberger v. Bracknell, 869 F.2d 1467 (11th Cir. 1989): Confirms that filing grievances is protected activity.
  • Castle v. Appalachian Tech. College, 631 F.3d 1194 (11th Cir. 2011): Emphasizes the causation requirement that the defendant be subjectively motivated by the protected speech to take the adverse action.
  • Miller v. Donald, 541 F.3d 1091 (11th Cir. 2008): Cited for rejecting “wildly implausible” allegations—supporting the conclusion that alleging retaliation by an official who repeatedly approved the relevant grievances is implausible absent more.
• Eighth Amendment—conditions of confinement:
  • Rhodes v. Chapman, 452 U.S. 337 (1981): The Eighth Amendment prohibits deprivations of “the minimal civilized measure of life’s necessities.”
  • Farmer v. Brennan, 511 U.S. 825 (1994): Establishes the two-step test—objective seriousness and subjective deliberate indifference.
  • Helling v. McKinney, 509 U.S. 25 (1993): The objective inquiry looks to whether the risk is so grave that exposure violates contemporary standards of decency.
  • Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004): Emphasizes the “high bar” for the objective prong; “mere discomfort” does not offend the Eighth Amendment.
  • Hudson v. McMillian, 503 U.S. 1 (1992): “Routine discomfort is part of the penalty” of imprisonment.
• Appellate authority:
  • Quality Auto Painting Ctr. of Roselle, Inc. v. State Farm Indem. Co., 917 F.3d 1249 (11th Cir. 2019): De novo review of dismissal.
  • Cuddeback v. Florida Bd. of Educ., 381 F.3d 1230 (11th Cir. 2004): The court may affirm on any ground supported by the record, regardless of the district court’s stated rationale. This supported affirming the Eighth Amendment dismissal on the merits without reaching the district court’s exhaustion ruling.

Legal Reasoning

First Amendment Retaliation: Causation and Plausibility

The court accepted that Moultrie engaged in protected speech (filing grievances) and that confiscating a mattress would deter an ordinary person, but it found causation implausible for two interlocking reasons:

• Approval of grievances undermines retaliatory motive. Edwards consistently approved the very class of grievances (about unsanitary conditions and cleaning supplies) that Moultrie identified as the precipitating speech. It is “wildly implausible” to infer that Edwards both approved those grievances and simultaneously punished Moultrie for submitting them.
• Legitimate disciplinary justification not plausibly alleged to be pretext. Moultrie admitted possessing contraband (an extra sheet and sugar packets). The record reflected that other prison officials corroborated that the mattress confiscation was disciplinary. The complaint did not allege coordination or pretext by those other officials, nor facts suggesting Edwards’s stated rationale was false.

Applying Iqbal/Twombly, the panel held the complaint did not plausibly allege Edwards “was subjectively motivated to take the adverse action because of the protected speech” (Castle). In short, the pleaded facts supported a non-retaliatory explanation (rule enforcement), not retaliation.

Eighth Amendment: Objective Seriousness Not Met

The panel resolved the Eighth Amendment claim at the first step of the Farmer framework. The objective prong asks whether the condition posed a substantial risk of serious harm that contemporary standards of decency deem intolerable (Helling; Chandler). The court characterized the harm from sleeping without a mattress for eighteen days as “uncomfortable” but not “wanton and unnecessary” or sufficiently grave to violate the Eighth Amendment. It emphasized:

• The Eleventh Circuit’s “high bar” for objective seriousness, where “mere discomfort” does not suffice (Chandler), and routine discomfort is part of incarceration (Hudson).
• The disciplinary context—this was a sanction for contraband—further counseled against deeming the condition “wanton and unnecessary.”

Because the objective component failed, the court did not reach deliberate indifference (the subjective component) or the district court’s exhaustion ruling. Invoking its authority to affirm on any legal ground (Cuddeback), the panel affirmed on the merits of the Eighth Amendment claim.

Procedural Posture: Affirmance on Any Ground

The panel noted its de novo review standard and its prerogative to affirm on any ground supported by the record. Although the district court dismissed the Eighth Amendment claim for failure to exhaust, the appellate court affirmed on an alternative ground—the objective deficiency of the claim—thus mooting the need to decide exhaustion. This is a practical illustration of appellate efficiency where a dispositive merits issue is straightforward.

Impact and Implications

• Retaliation pleading in prisoner cases. Merely alleging protected activity and adverse action is insufficient. Where the defendant’s conduct includes approving the very grievances at issue and a plausible non-retaliatory reason exists (discipline for admitted contraband), plaintiffs must plead concrete facts showing retaliatory motive or pretext. Temporal proximity or labels alone will not clear Iqbal/Twombly.
• Conditions-of-confinement threshold in the Eleventh Circuit. The decision reinforces that short-term deprivation of a mattress—here, eighteen days—standing alone is generally viewed as “mere discomfort” and not “objectively, sufficiently serious.” Claims may require aggravating factors (e.g., extreme cold, unsanitary conditions, medical vulnerability, or far longer durations) to meet the objective prong.
• Disciplinary context matters. When a condition arises as a sanction for a rule violation, courts are less likely to characterize it as “wanton and unnecessary” absent disproportionate severity or accompanying risks.
• Appellate strategy and exhaustion. Although the Prison Litigation Reform Act’s exhaustion requirement remains mandatory, an appellate court may affirm on an alternative merits ground if it is clear and dispositive. Litigants should brief both exhaustion and merits robustly on appeal.
• Persuasive, not binding. This opinion is unpublished and therefore not binding precedent in the Eleventh Circuit. Nonetheless, it offers persuasive guidance on (a) how grievance approvals can defeat retaliation causation at the pleading stage and (b) where the circuit currently draws the objective line for mattress-deprivation claims.

Complex Concepts Simplified

• Plausibility (Twombly/Iqbal): Courts do not accept mere conclusions. The complaint must include facts that make the alleged misconduct reasonably believable, not just possible. If an obvious, lawful explanation fits the facts better (e.g., discipline for contraband), a plaintiff must plead facts showing why that explanation is pretextual.
• Retaliation elements:
  1. Protected speech (e.g., filing grievances).
  2. Adverse action that would deter an ordinary person.
  3. Causation—defendant acted because of the protected speech. This often requires factual allegations of motive, such as statements, timing plus other indicia, disparate treatment, or implausibility of the proffered reason.
• Eighth Amendment—two-part test:
  1. Objective: Was the condition so serious that it posed a substantial risk of significant harm by contemporary standards of decency?
  2. Subjective: Did the official know of and disregard that risk (deliberate indifference)?
  Failing the objective step ends the claim.
• “Affirm on any ground”: An appellate court can uphold a judgment even if it relies on a different legal reason than the one the lower court used, so long as the record supports the alternative ground.
• Exhaustion (PLRA): Prisoners must properly complete the prison grievance process before suing. Here, the panel did not decide exhaustion because the claim failed on the merits.

Conclusion

The Eleventh Circuit’s unpublished decision in Moultrie v. Edwards offers two clear guideposts for prisoner civil-rights litigation in the circuit. First, pleading a retaliation claim requires more than alleging protected activity and an adverse action; where the defendant’s conduct includes approving the very grievances at issue and there is an admitted, legitimate disciplinary rationale, causation will be deemed implausible absent specific facts of pretext or retaliatory motive. Second, an eighteen-day deprivation of a mattress, without more, does not satisfy the Eighth Amendment’s objective threshold; “mere discomfort” does not equate to unconstitutional conditions.

Beyond its immediate facts, the opinion underscores the continuing force of the Twombly/Iqbal pleading standards in pro se prisoner suits, the Eleventh Circuit’s high bar for conditions-of-confinement claims, and the appellate court’s readiness to affirm on any legally sound ground. While not precedential, the case provides practical, persuasive guidance: to survive dismissal, retaliation complaints must grapple with obvious non-retaliatory explanations, and Eighth Amendment claims grounded in short-term discomfort require aggravating factors to cross the constitutional line.