Hall v. Masters: Dual-Standard Failure of Proof in Civil Detainee Water-Safety Claims and Discretion to Deny Court-Appointed Experts and Deposition Assistance

Introduction

In Wendall Jermaine Hall v. Malinda Masters, No. 24-11879 (11th Cir. Nov. 5, 2025) (per curiam) (unpublished), the Eleventh Circuit affirmed the grant of summary judgment for a Florida civil commitment administrator and upheld several discovery- and litigation-management rulings adverse to a pro se civil detainee.

The plaintiff, a civil detainee at the Florida Civil Commitment Center (FCCC), brought a 42 U.S.C. § 1983 action alleging that the FCCC administrator, Malinda Masters, violated his Fourteenth Amendment due process rights by failing to provide safe drinking water, which he claimed caused him illness. Hall also challenged the magistrate judge’s denials—affirmed by the district court—of his motions to appoint counsel, to appoint a designated deposition officer, and to appoint an expert witness to conduct a water analysis.

The appeal presented two clusters of issues:

Whether summary judgment was proper on a civil detainee’s Fourteenth Amendment conditions-of-confinement claim sounding in allegedly unsafe water, under either the Youngberg “professional judgment” standard or the Eighth Amendment–derived “deliberate indifference” test applied to Fourteenth Amendment claims.
Whether the district court abused its discretion in denying requests for appointed counsel, a Rule 706 expert, and deposition assistance for a pro se litigant.

Summary of the Opinion

The court affirmed the denial of appointed counsel, a designated deposition officer, and a court-appointed expert. It held that the district court did not abuse its discretion: no “exceptional circumstances” warranted counsel; a deposition officer need not be appointed for a pro se prisoner; and a Rule 706 expert was unnecessary where reliable water-testing evidence already existed and had not been impeached.
On the merits, the Eleventh Circuit affirmed summary judgment for the administrator. The panel concluded that Hall failed to create a genuine dispute of material fact under either (a) the Youngberg professional judgment standard, or (b) the Eighth Amendment–derived deliberate indifference framework applied to Fourteenth Amendment conditions claims. The unrebutted record showed the FCCC used county-supplied water tested monthly; the administrator also arranged annual testing; she personally consumed the water without issue; and Hall’s health complaints predated his water-related allegations.
Because the outcome was the same under both legal standards, the court did not need to resolve any potential doctrinal tension between them in the civil commitment context.

Detailed Analysis

Standards of Review

The court reviewed the denial of appointed counsel, discovery rulings (including the deposition officer request), and appointment of an expert for abuse of discretion. Summary judgment was reviewed de novo, with all reasonable inferences drawn in favor of the nonmovant and no weighing of credibility. See Fed. R. Civ. P. 56(a); Reeves v. Sanderson Plumbing Products, Inc. (2000).

Precedents Cited and Their Role

Bass v. Perrin (11th Cir. 1999) — Cited for abuse-of-discretion review of a district court’s refusal to appoint counsel or experts. The panel applied this deferential lens to uphold the magistrate judge’s rulings.
Fed. R. Evid. 706(a) and Quiet Tech. DC-8, Inc. v. Hurel-Dubois UK Ltd. (11th Cir. 2003) — Rule 706 allows a court to appoint a neutral expert. Quiet Tech underscores that such appointments are discretionary, so long as the court thoroughly considers the request and reasonably explains the decision. Here, the magistrate explained that water testing was already available and not shown unreliable, so a court-appointed expert was unnecessary.
Kilgo v. Ricks (11th Cir. 1993) and 28 U.S.C. § 1915(e)(1) — No absolute constitutional right to counsel in civil cases; courts may request volunteer counsel in “exceptional circumstances.” The panel agreed that Hall did not demonstrate exceptional circumstances under the totality of circumstances.
DeJesus v. Lewis (11th Cir. 2021) — Identifies factors for appointing counsel: complexity, the plaintiff’s ability to present and investigate, necessity of skilled evidence presentation, and whether counsel would aid the court. Applying these factors, the court found appointment unwarranted.
Smith v. School Board of Orange County (11th Cir. 2007) — Discovery rulings are reviewed for abuse of discretion. The panel relied on this baseline to affirm the denial of deposition assistance.
Rodriguez v. Burnside (11th Cir. 2022) — Upholds denial of a pro se prisoner’s request to compel depositions where other evidentiary avenues exist, there is no good-faith effort to resolve disputes, and the depositions would be disproportionately burdensome. The panel analogized to affirm denial of a designated deposition officer for Hall.
Brown v. Crawford (11th Cir. 1990), Fed. R. Civ. P. 56(a), and Reeves — Articulate the de novo review and familiar summary judgment standards.
42 U.S.C. § 1983 — Provides the cause of action for violations of federal rights under color of state law.
Bilal v. Geo Care, LLC (11th Cir. 2020) and Dolihite v. Maughon (11th Cir. 1996) — Confirm that civil detainees’ Fourteenth Amendment substantive due process protections are at least equivalent to prisoners’ Eighth Amendment protections, and that the civilly committed are owed a higher standard of care because their confinement is not punitive.
Youngberg v. Romeo (U.S. 1982) — Sets the “professional judgment” standard for conditions affecting those civilly committed: courts defer to decisions of qualified professionals unless the decision is a substantial departure from accepted professional judgment, practice, or standards, signaling it was not actually based on professional judgment.
Farmer v. Brennan (U.S. 1994) and Estelle v. Gamble (U.S. 1976) — Define Eighth Amendment duties regarding basic needs and medical care and the “deliberate indifference” concept.
Wade v. McDade (11th Cir. 2024) (en banc) and Swain v. Junior (11th Cir. 2020) — Under the Eighth Amendment–derived framework applied to Fourteenth Amendment conditions claims, a plaintiff must show (1) an objectively substantial risk of serious harm and (2) the defendant’s subjective recklessness—actual awareness that the defendant’s conduct caused a substantial risk and disregard of that risk. A reasonable response to known risk defeats deliberate indifference.

Legal Reasoning

1) Discretionary denials: counsel, deposition officer, and Rule 706 expert

The panel held the district court did not abuse its discretion in denying Hall’s motions:

Appointed counsel: Applying § 1915(e)(1), Kilgo, and DeJesus, the court saw no exceptional circumstances. Hall’s case did not present extraordinary factual or legal complexity, and he could present the core of his claim pro se.
Designated deposition officer: Relying on Smith and Rodriguez, the court concluded there is no obligation to equip a pro se prisoner with special deposition machinery, particularly where alternative discovery methods exist and depositions would be burdensome and disproportionate.
Rule 706 expert: The magistrate judge reasonably explained that municipal and facility testing already provided water-quality evidence, and Hall had not shown that testing untrustworthy. Because Rule 706 experts are neutral aids for the court—not advocates to fill a party’s evidentiary gaps—the denial was within the court’s discretion.

2) Summary judgment on the Fourteenth Amendment conditions claim

The court evaluated Hall’s unsafe-water claim under both doctrinal lenses and found it wanting under each:

Youngberg professional judgment: The record reflected that FCCC used county water, which the county tests monthly; the administrator conducted annual testing; and she herself consumed the water without incident. Hall offered no evidence showing that Masters’s decisions were a substantial departure from accepted professional judgment. On that record, deference to professional judgment controlled.
Deliberate indifference (Eighth Amendment–derived): Hall failed to raise a triable issue on either prong. Objectively, the testing regime and lack of identified contamination undermined any showing of a substantial risk of serious harm. Subjectively, there was no evidence that Masters actually perceived, yet disregarded, such a risk; indeed, all evidence suggested ongoing monitoring and reasonable responses. Hall’s health issues predated his water complaints, weakening causation and awareness inferences.

Because Hall could not create a genuine dispute of material fact under either standard, summary judgment for Masters was affirmed.

Impact and Practical Implications

Although unpublished, the decision carries persuasive weight within the Eleventh Circuit and offers several practical lessons:

Civil detainee water-quality claims demand concrete proof. Allegations of tainted water, without competent evidence showing contamination or policy-level disregard, will not survive summary judgment. Reliance on municipal water and routine testing constitutes powerful defense evidence.
Youngberg vs. deliberate indifference often won’t change the outcome without evidence. Where the record shows ongoing professional measures to ensure safety, a plaintiff’s claim will fail irrespective of whether the court analyzes under professional judgment or deliberate indifference.
Rule 706 experts are not a substitute for a party’s proof. The court reaffirmed the limited, neutral role of court-appointed experts and the broad discretion to deny appointment when reliable, accessible testing already exists.
Pro se discovery assistance is limited. Courts are not required to appoint deposition officers or counsel to facilitate discovery for incarcerated litigants, particularly where less burdensome alternatives exist (e.g., document requests, interrogatories, requests for admissions, declarations/affidavits, Rule 31 depositions on written questions).
Medical causation matters. To link health issues to water quality, plaintiffs typically need medical evidence that traces specific contaminants to specific conditions and timing, alongside proof that facility officials knew and ignored risks.

Complex Concepts Simplified

42 U.S.C. § 1983: A federal civil remedy that lets individuals sue state actors for violations of federal rights.
Civil detainee vs. prisoner: Civil detainees (e.g., those committed for treatment) are confined for nonpunitive reasons, unlike prisoners serving criminal sentences. Their rights arise under the Fourteenth Amendment’s Due Process Clause, not the Eighth Amendment—but courts often look to Eighth Amendment standards for guidance.
Professional judgment (Youngberg): Courts defer to decisions by qualified professionals unless the decision substantially departs from accepted professional standards—meaning it wasn’t truly based on professional judgment.
Deliberate indifference: A two-part test requiring (1) an objectively serious risk of harm and (2) proof that the official actually knew of, and recklessly disregarded, that risk. Reasonable responses defeat liability.
Summary judgment: A pretrial judgment entered when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.
Abuse of discretion: A deferential review standard; the appellate court asks whether the lower court made a reasonable decision within the range of permissible choices.
Rule 706 expert: A neutral expert appointed by the court to assist the court in understanding complex evidence. This is different from a party’s retained expert advocate.
Per curiam; non-argument calendar; unpublished: A short, unsigned decision issued without oral argument; unpublished opinions are not binding precedent but may be persuasive.

Doctrinal Clarifications and Nuances

This opinion illustrates, rather than resolves, a nuanced doctrinal landscape in the Eleventh Circuit:

Equivalence but not identity: Bilal and Dolihite affirm that civil detainees’ protections are at least equivalent to prisoners’ Eighth Amendment rights, yet Youngberg supplies an independent professional judgment framework in civil commitment settings.
Convergence in practice: Where the record shows reasonable, documented safety measures (e.g., reliance on municipal water subject to monthly testing plus facility-level annual testing), claims generally fail under both standards; thus, the choice of standard may be outcome-neutral when proof is thin.
Wade’s subjective prong remains key: The en banc decision in Wade confirms that deliberate indifference in this circuit includes a subjective awareness requirement. The court’s application here reflects that an official’s reasonable, documented response defeats the subjective prong.

What Evidence Would Likely Have Changed the Outcome

For future litigants, the opinion implicitly signals what kinds of proof matter in unsafe-water and similar conditions claims:

Objective evidence of contamination or violations of regulatory standards (e.g., lab reports showing exceedances of lead, copper, arsenic, nitrates, E. coli, disinfection byproducts, or other contaminants), temporally linked to the alleged harms.
Documentation that facility officials knew of and disregarded risks (e.g., prior positive tests, internal emails, ignored maintenance orders, resident complaints coupled with warnings from public health agencies).
Medical evidence tying health conditions to specific contaminants and exposure windows, and ruling out plausible alternative causes.
Evidence undermining the reliability of the existing testing regime (e.g., chain-of-custody issues, methodological flaws, conflicts of interest, or missed testing intervals).
Proof that professional norms required additional steps the facility failed to take (e.g., corrosion control, point-of-use filters during known system upsets), supporting a “substantial departure” under Youngberg.

Conclusion

Hall v. Masters is a careful application of settled law to a sparse record. The Eleventh Circuit affirmed that, absent exceptional circumstances, district courts may deny pro se requests for counsel, court-appointed experts, and special deposition assistance. On the merits, the court underscored that civil detainee conditions claims premised on unsafe water require concrete, conflicting evidence to overcome a record of municipal supply, routine testing, and reasonable professional responses.

Two doctrinal tracks—Youngberg’s professional judgment and the Eighth Amendment–derived deliberate indifference standard—converged on the same conclusion: Hall did not create a genuine dispute of material fact. The decision thus reinforces a pragmatic rule of proof for civil detainee safety claims in this circuit: where an institution documents consistent reliance on public water systems and routine testing, plaintiffs must marshal specific, credible evidence of contamination, causation, and either a substantial professional departure or subjective recklessness. Without that, summary judgment is appropriate.