Introduction

In Eddie James Moultrie v. G. Edwards (11th Cir. Sept. 11, 2025) (unpublished, non-argument calendar), the Eleventh Circuit affirmed the dismissal of a pro se prisoner’s 42 U.S.C. § 1983 lawsuit against a prison lieutenant. The case sits at the intersection of First Amendment retaliation doctrine and the Eighth Amendment’s conditions-of-confinement jurisprudence, framed by modern pleading standards under Twombly and Iqbal.

The plaintiff, an inmate in the Florida Department of Corrections, alleged that Lieutenant Edwards retaliated against him for filing grievances about unsanitary cell conditions and inadequate cleaning supplies by confiscating his mattress and placing him on “meal management” for two meals. He also alleged that sleeping on a metal bunk without a mattress for eighteen days constituted cruel and unusual punishment.

The district court dismissed the First Amendment claim for failure to plausibly allege retaliatory motive and dismissed the Eighth Amendment claim for failure to exhaust administrative remedies. On appeal, the Eleventh Circuit affirmed, holding that the complaint failed to state a claim. As to retaliation, the court found no plausible causal link between the protected grievances and the discipline, particularly because Edwards had approved the very grievances at issue and there was an undisputed, non-retaliatory reason for the discipline (contraband). As to the Eighth Amendment, the court held that an eighteen-day deprivation of a mattress, while uncomfortable, does not cross the “objective seriousness” threshold. The panel did not reach exhaustion.

Parties: Plaintiff-Appellant Eddie James Moultrie; Defendant-Appellee Lieutenant G. Edwards. Appeal from the Middle District of Florida (No. 2:23-cv-00416-JLB-KCD). Panel: Circuit Judges Grant, Lagoa, and Wilson. Per curiam.

Summary of the Opinion

The Eleventh Circuit reviewed de novo the district court’s dismissal for failure to state a claim. Accepting the complaint’s well-pleaded factual allegations as true, the court held:

• First Amendment retaliation: Although filing grievances is protected speech and losing a mattress qualifies as an adverse action that would deter an ordinary prisoner, the complaint did not plausibly allege causation. Two facts defeated a reasonable inference of retaliatory motive: (1) Edwards approved all of Moultrie’s grievances about cleaning and sanitation; and (2) Moultrie admitted he possessed contraband (an extra bedsheet and sugar packets), and other prison officials confirmed that the mattress was confiscated as discipline for that infraction. The complaint did not plausibly allege pretext or collusion.
• Eighth Amendment conditions claim: Applying Farmer v. Brennan’s two-part test, the court resolved the claim at the first, “objective” step, holding that eighteen days without a mattress, though uncomfortable and painful, is not the kind of “sufficiently serious” deprivation that violates contemporary standards of decency. Because the claim failed on the merits, the court did not address the district court’s exhaustion ruling.

Result: Affirmed. All pending motions denied as moot.

Detailed Analysis

Factual context in focus

The opinion’s facts matter to the plausibility analysis:

• Moultrie’s initial grievances complained about a dirty cell and inadequate cleaning supplies. Edwards approved those grievances and directed staff to provide brooms and mops.
• After a toilet flood, Moultrie escalated the sanitation complaints; Edwards again approved and directed staff to give him what he requested.
• Edwards also directed an officer to clean Moultrie’s cell. The officer found contraband: an extra sheet and sugar packets (violating rules against extra items and food in cells).
• Edwards confiscated the mattress as discipline for the extra sheet and imposed “meal management” for two meals for the sugar packets.
• Moultrie alleged he slept on the metal frame for eighteen days and experienced back and hip pain. He filed numerous grievances at various levels.

Precedents cited and how they shaped the decision

• Pleading standards and review:
  • Quality Auto Painting Ctr. of Roselle, Inc. v. State Farm Indem. Co. (11th Cir. 2019): De novo review of Rule 12(b)(6) dismissals; accept well-pleaded facts as true; draw reasonable inferences in plaintiff’s favor.
  • Ashcroft v. Iqbal (U.S. 2009) and Bell Atl. Corp. v. Twombly (U.S. 2007): Plausibility is required; factual allegations must allow a reasonable inference of liability and rise above speculation.
  • Alba v. Montford (11th Cir. 2008): Liberal construction of pro se complaints does not relax the requirement to plead sufficient facts.
  • Cuddeback v. Florida Bd. of Educ. (11th Cir. 2004): The court may affirm on any ground supported by the record, regardless of the district court’s reasoning. The panel used this avenue to affirm the Eighth Amendment dismissal on merits rather than exhaustion.
• First Amendment retaliation:
  • Smith v. Mosley (11th Cir. 2008): Elements of a prisoner-retaliation claim—protected speech, adverse action that would deter an ordinary person, and a causal connection (the official was subjectively motivated by the protected speech).
  • Wildberger v. Bracknell (11th Cir. 1989): Filing grievances is protected activity.
  • Castle v. Appalachian Tech. Coll. (11th Cir. 2011): Causation requires that the defendant was subjectively motivated to take the adverse action because of the protected speech.
  • Miller v. Donald (11th Cir. 2008): Allegations can be implausible where the pleaded facts undercut the asserted inference (the panel quotes “wildly implausible” in rejecting motive pled).
• Eighth Amendment conditions of confinement:
  • Rhodes v. Chapman (U.S. 1981): The Eighth Amendment protects the “minimal civilized measure of life’s necessities.”
  • Farmer v. Brennan (U.S. 1994): Two-pronged analysis—objective substantial risk of serious harm and subjective deliberate indifference.
  • Helling v. McKinney (U.S. 1993) and Chandler v. Crosby (11th Cir. 2004): The objective prong poses a high bar; the risk must be so grave that exposing anyone to it violates contemporary standards of decency.
  • Hudson v. McMillian (U.S. 1992): “Routine discomfort” is part of the penalty criminal offenders pay; not every discomfort amounts to cruel and unusual punishment.

Legal reasoning

First Amendment retaliation—causation and plausibility

The court accepted that Moultrie’s filing of grievances was protected and that confiscating a mattress (and imposing “meal management”) would deter a person of ordinary firmness. The dispositive issue was causation—did Edwards take the adverse actions because of Moultrie’s protected speech?

Two pleaded facts undercut retaliation:

• Edwards repeatedly approved the very grievances that Moultrie claimed triggered the retaliation—those about unsanitary conditions and lack of supplies. An official who grants the requested relief lacks an obvious retaliatory motive against that speech. The court called the contrary inference “wildly implausible” (citing Miller).
• Moultrie admitted contraband possession, and other officials’ grievance responses confirmed that the mattress confiscation was imposed as discipline for the rule violation. The complaint did not allege collusion or facts suggesting the proffered disciplinary reason was pretext for punishing protected speech.

Framed in Twombly/Iqbal terms, the complaint presented an “obvious alternative explanation” for the adverse actions—discipline for contraband—that rendered the retaliation inference implausible absent additional factual content pointing to retaliatory animus (for example, inconsistent enforcement, statements showing hostility to grievances, or timing that aligns only with grievance activity and not the intervening disciplinary trigger).

Eighth Amendment—objective seriousness and context of short-term disciplinary measures

Applying Farmer’s two-step test, the panel decided the claim at the threshold objective prong. It held that eighteen days of sleeping without a mattress, even with alleged back and hip pain, is not an “objectively, sufficiently serious” deprivation. The court emphasized:

• The Eighth Amendment bars deprivations that violate “contemporary standards of decency,” not every uncomfortable or harsh condition.
• “Routine discomfort” is part of incarceration, especially when arising from discipline for rule violations.
• The asserted harm, while nontrivial, did not rise to the level of “wanton and unnecessary” pain or extreme conditions contemplated by Chandler and Helling.

Because the objective component failed, the court did not reach the subjective component (deliberate indifference) and, invoking Cuddeback’s “affirm on any ground” rule, had no need to resolve the district court’s exhaustion rationale.

Impact and implications

Pleading prisoner retaliation in the Eleventh Circuit

• Approval of the underlying grievances is strong evidence against retaliatory motive. Where the defendant granted the relief sought, a plaintiff must plead specific facts overcoming the inference of neutrality (e.g., statements of hostility, a pattern of adverse actions tied to grievance activity, or disparate enforcement).
• A legitimate disciplinary basis, especially one corroborated by undisputed facts (like admitted contraband) and third-party confirmations, will typically defeat retaliation claims at the pleading stage unless supported by plausible allegations of pretext.
• Temporal proximity alone is usually insufficient where an intervening event (here, a contraband discovery) provides an obvious non-retaliatory cause for the adverse action.

Conditions-of-confinement litigation: what counts as “objectively serious”?

• The decision reinforces the high threshold for Eighth Amendment conditions claims, particularly for short-term deprivations imposed as discipline. An eighteen-day deprivation of a mattress, standing alone, is not “objectively serious” within this Circuit’s framework.
• The analysis was fact-specific. Different facts could change the outcome—e.g., much longer durations, concurrent deprivations compounding the risk (extreme cold, lack of blankets, exposure to raw sewage), medical contraindications ignored by staff, or demonstrable lasting injury coupled with deliberate indifference.
• Plaintiffs should plead the full conditions matrix (duration, severity, cumulative effect, medical consequences, requests for medical attention, and officials’ responses) to meet Farmer’s objective and subjective components.

Exhaustion under the PLRA

Although the district court dismissed the Eighth Amendment claim for failure to exhaust, the panel affirmed on the merits and did not reach exhaustion. Defense counsel should still raise exhaustion early; plaintiffs should document compliance with grievance procedures and articulate how each specific condition was exhausted. The case shows that appellate courts may bypass exhaustion disputes if a claim fails on the merits.

Persuasive, not binding—but anchored in binding doctrine

The decision is unpublished and therefore non-precedential in the Eleventh Circuit. Nonetheless, it is likely to be cited persuasively in district courts given its reliance on core Supreme Court and Eleventh Circuit precedents (Twombly/Iqbal, Farmer, Chandler, Smith v. Mosley).

Practice pointers

• For plaintiffs:
  • Retaliation: Plead concrete facts indicating pretext—e.g., statements, inconsistent discipline compared to similarly situated inmates, suspicious timing not explainable by intervening discipline, or departures from written policy.
  • Conditions: Detail duration, frequency, environmental factors (temperature, sanitation), medical impact, requests for treatment, and defendants’ knowledge and responses.
  • Exhaustion: Attach or describe all grievance steps taken for the specific condition challenged and the relief sought at each stage.
• For defendants:
  • Retaliation: Highlight approvals of the underlying grievances and any neutral or mandatory disciplinary reasons, with references to grievance responses or disciplinary reports.
  • Conditions: Emphasize short duration, availability of alternatives (blankets), and absence of extreme factors; invoke Hudson and Chandler’s “routine discomfort” principle.
  • Preserve multiple defenses: move to dismiss for failure to state a claim and for failure to exhaust, recognizing the appellate court may affirm on either ground.

Complex Concepts Simplified

• Plausibility (Twombly/Iqbal): A complaint must contain enough factual content to allow a reasonable inference of liability. Courts disregard conclusory statements and demand more than speculative possibilities.
• First Amendment retaliation elements:
  • Protected activity: Here, filing prison grievances.
  • Adverse action: Something that would deter an ordinary person from continuing that activity (e.g., mattress confiscation).
  • Causation: The defendant acted because of the protected activity (subjective motivation). Plaintiffs must show more than timing—facts that tie the action to the speech.
• Eighth Amendment conditions of confinement:
  • Objective prong: The condition must pose a substantial risk of serious harm—far beyond discomfort.
  • Subjective prong: Officials must be deliberately indifferent—aware of and disregarding the risk.
  • Short-term, discomforting discipline for rule violations typically does not meet this standard absent aggravating circumstances.
• “Affirm on any ground”: An appellate court can uphold a lower court’s judgment based on any valid legal reason supported by the record, even if the district court relied on a different rationale.
• “Meal management”: A reduction in meal portions or content for disciplinary reasons. In this case it was imposed for two meals; the opinion did not resolve a stand-alone Eighth Amendment challenge to that measure.

Conclusion

Moultrie v. Edwards underscores two durable points in prisoner litigation. First, retaliation claims will not survive the pleadings where the defendant approved the grievances at issue and a neutral, well-pleaded disciplinary reason (contraband) explains the adverse action; allegations of retaliatory motive must be supported by concrete facts suggesting pretext. Second, short-term deprivation of a mattress—here, eighteen days—does not satisfy the Eighth Amendment’s objective seriousness requirement, particularly when imposed as discipline for a rule infraction.

Although unpublished, the decision aligns with binding Supreme Court and Eleventh Circuit precedent and will likely guide district courts in screening and resolving similar § 1983 claims. For prisoners, the ruling signals the need for detailed factual allegations tying officials’ actions to protected speech and demonstrating truly extreme or compounding conditions. For correctional officials, it confirms that enforcing rules through measured, time-limited disciplinary measures generally withstands constitutional scrutiny, especially at the Rule 12(b)(6) stage.