Reaffirming Subjective Recklessness and Pleading Specificity in Prisoner Suits: Beaubrun v. Dodge State Prison

Court: U.S. Court of Appeals for the Eleventh Circuit (Non-Argument Calendar, unpublished)
Date: August 29, 2025
Docket No.: 23-12757
Panel: Judges Newsom, Grant, and Luck (per curiam)

Introduction

This appeal arises from a pro se, in forma pauperis action brought under 42 U.S.C. § 1983 by state prisoner Thony Beaubrun against staff at Dodge State Prison (Warden Tommy Bowen, Counselor Bray, Lieutenant Bray, and Officer Bentley) in both their individual and official capacities. Beaubrun alleged a suite of constitutional violations stemming from a June 12, 2022 inmate-on-inmate attack and the prison’s subsequent handling of his medical care, brief administrative segregation, and later transfer to Riverbend Correctional Facility.

At screening under 28 U.S.C. § 1915A, the district court dismissed the complaint for failure to state a claim. On appeal, the Eleventh Circuit affirmed. While unpublished and thus non-precedential, the opinion is doctrinally significant for three reasons:

It applies the Eleventh Circuit’s en banc decision in Wade v. McDade to underscore that Eighth Amendment claims turn on “subjective recklessness,” not mere negligence, and that defendants’ reasonable responses negate liability—even if harm occurs.
It demands concrete, non-conclusory factual allegations at the pleading stage—consistent with Twombly/Iqbal—to show officials’ subjective knowledge of risk and a reasonable opportunity to intervene.
It reaffirms Sandin v. Conner and Meachum v. Fano: short-term administrative segregation and intrastate transfers ordinarily do not trigger liberty interests protected by procedural due process, absent allegations of sentence impact or atypical and significant hardship relative to ordinary prison life.

Summary of the Judgment

Eighth Amendment—Failure to Protect/Intervene: Dismissal affirmed. The complaint lacked facts showing defendants’ subjective knowledge of a specific, substantial risk to Beaubrun or their ability to reasonably intervene during the attack without undue risk. Generalized complaints about a “high-risk” dorm were insufficient.
Eighth Amendment—Deliberate Indifference to Medical Needs: Dismissal affirmed. The allegations showed officers took Beaubrun directly to medical after the attack; staffing shortages delayed treatment; he later received ibuprofen. The complaint did not plausibly allege an objectively serious medical need obvious to a layperson or subjective recklessness by the officers.
Fourteenth Amendment—Procedural Due Process (Segregation and Transfer): Dismissal affirmed. Ten-day administrative segregation in hot conditions was not alleged to affect sentence duration or impose “atypical and significant hardship” relative to ordinary prison life. Transfer to Riverbend did not implicate a liberty interest.
New Arguments on Appeal: Forfeited. Claims first raised on appeal or after the district court limited amendment (including equal protection, state-law conviction challenges, property searches, and a “sale” to a private prison) were not considered.
Disposition: Affirmed in full.

Analysis

Precedents Cited and How They Shaped the Decision

Farmer v. Brennan, 511 U.S. 825 (1994): Cornerstone for Eighth Amendment conditions claims. The court reiterated Farmer’s two-part test: (1) objectively substantial risk of serious harm; and (2) subjective deliberate indifference (the official knows of and disregards an excessive risk). Farmer also recognizes that reasonable responses defeat liability even if harm occurs. This framework controlled both the failure-to-protect and medical-indifference analyses.
Wade v. McDade, 106 F.4th 1251 (11th Cir. 2024) (en banc): The Eleventh Circuit’s definitive statement that the Eighth Amendment’s mental state is subjective recklessness as in criminal law, replacing any “more-than-gross-negligence” gloss. The panel leaned on Wade to emphasize that officers must be actually, subjectively aware that their own conduct created a substantial risk of serious harm, and that reasonable responses negate liability.
Estelle v. Gamble, 429 U.S. 97 (1976): Established that deliberate indifference to serious medical needs violates the Eighth Amendment; mere negligence or disagreement with medical judgment does not. The court used Estelle to show that triage decisions and non-immediate treatment—without more—do not amount to constitutional violations.
Hoffer v. Secretary, Fla. Dep’t of Corr., 973 F.3d 1263 (11th Cir. 2020) and Farrow v. West, 320 F.3d 1235 (11th Cir. 2003): Define an “objectively serious medical need” (either diagnosed as requiring treatment or obvious to a layperson, and posing substantial risk if untreated). The panel used these to conclude that unspecified injuries described as “permanent,” without detail, did not plausibly allege objective seriousness.
Brown v. Hughes, 894 F.2d 1533 (11th Cir. 1990) and Davidson v. Cannon, 474 U.S. 344 (1986): Negligence cannot ground a § 1983 claim for failure to protect—deliberate indifference is required. The court invoked these to reject conclusory allegations and generalized fears.
McCoy v. Webster, 47 F.3d 404 (11th Cir. 1995): When officials are aware of threats, they must afford reasonable protection. The panel applied this to highlight the absence of facts showing officers could reasonably intervene during the attack.
Sandin v. Conner, 515 U.S. 472 (1995): A liberty interest for procedural due process exists if segregation inevitably affects sentence duration or imposes an atypical and significant hardship relative to ordinary prison life. The court found neither was plausibly alleged for a 10-day segregation with general heat complaints.
Meachum v. Fano, 427 U.S. 215 (1976): No liberty interest in avoiding transfer between state prisons; transfers are within the normal range of custody authorized by a conviction. This foreclosed the due process challenge to Beaubrun’s transfer to Riverbend.
Twombly, 550 U.S. 544 (2007) and Iqbal, 556 U.S. 662 (2009): Plausibility pleading standard: facts must allow a reasonable inference of liability; labels and conclusions are insufficient. The court repeatedly relied on these to stress the lack of factual content (e.g., who attacked, where officers stood, how they could intervene, injury specifics).
West v. Atkins, 487 U.S. 42 (1988) and Zatler v. Wainwright, 802 F.2d 397 (11th Cir. 1986): § 1983 requires a deprivation of federal rights by a person acting under color of state law and an affirmative causal connection between the official’s acts and the deprivation. The theft of funds by inmates, without state-actor involvement or knowledge, could not be tied to an Eighth Amendment duty to ensure “reasonable safety.”
United States v. Campbell, 26 F.4th 860 (11th Cir. 2022) and Waldron v. Spicher, 954 F.3d 1297 (11th Cir. 2020): Forfeiture of arguments not raised below. These decisions supported the refusal to entertain new Fourth, Fifth, and Fourteenth Amendment theories advanced for the first time on appeal.
Thomas v. Bryant, 614 F.3d 1288 (11th Cir. 2010): Illustrates waiver/forfeiture when issues are raised post-judgment. Applied to reject a late-raised “sale to a private prison” claim.

Legal Reasoning

1) Eighth Amendment—Failure to Protect/Intervene

To state a failure-to-protect claim, a prisoner must plausibly allege both an objectively substantial risk and subjective deliberate indifference. The panel agreed with the district court that the complaint fell short on the subjective prong.

Generalized risk vs. specific threat: Allegations that Dorm A-3 was “high-risk” and fostered drugs, tobacco, and violence lacked the specificity Farmer requires. No facts showed that any defendant knew about a specific threat to Beaubrun from particular inmates and ignored it.
Failure to intervene during an attack: The complaint did not state where the officers were situated, how the attack unfolded, or whether intervention would have been feasible without undue risk to staff. Without facts showing an opportunity for “reasonable protection,” the court could not infer deliberate indifference.
Alleged theft during segregation: The claim that two inmates stole $67,000 from his bank account while he was in segregation—characterized as a failure to protect—did not implicate his health or safety and lacked any allegation that officers knew of or could prevent the theft. As pled, it could not satisfy Farmer’s subjective knowledge requirement or establish a constitutional duty to protect property against third-party theft.

2) Eighth Amendment—Deliberate Indifference to Medical Needs

Objective seriousness: The complaint stated that Beaubrun sustained head, knee, and arm injuries that were “permanent,” but included no detail indicating obvious seriousness to a layperson or that, if untreated, these injuries posed a substantial risk of serious harm.
Subjective recklessness and reasonable response: The pleading itself showed that officers took him directly to the medical department after the attack. Medical staff, facing a staffing shortage, deferred immediate treatment; later, he was recalled and prescribed ibuprofen. Under Wade and Farmer, such a prompt referral to medical care is a reasonable response that negates deliberate indifference by custodial officers. Disagreement with the adequacy of treatment, or unavailability of an X-ray machine at that moment, falls into medical judgment or resource limitation, not constitutional cruelty.

3) Fourteenth Amendment—Procedural Due Process (Administrative Segregation and Transfer)

Administrative segregation: Under Sandin, a protected liberty interest arises only if segregation inevitably affects sentence length or imposes an atypical and significant hardship relative to ordinary prison life. The complaint alleged 10 days in “the hole” with temperatures around 100 degrees but did not tie those conditions to sentence impact or demonstrate how the conditions differed from ordinary prison conditions in a way that was atypical and significant.
Transfer to Riverbend: Meachum forecloses a liberty interest in a particular prison placement. A transfer within the state system—even if displeasing or allegedly retaliatory—does not, without more, constitute a procedural due process violation.

4) New Theories on Appeal—Forfeiture

The court declined to consider new claims first presented on appeal or in late motions below, including equal protection, unlawful search of property, state-law conviction challenges, and a Fifth Amendment “sale” to a private facility. Eleventh Circuit law bars such late-breaking theories absent extraordinary circumstances, which were not present.

Impact

Heightened factual specificity at screening: The decision signals rigorous application of Twombly/Iqbal to prisoner civil rights suits even at § 1915A screening. Plaintiffs must plead concrete facts showing officials’ subjective knowledge of a specific risk and a feasible opportunity to respond.
Wade’s consolidation of the mental-state standard: By invoking Wade’s “subjective recklessness” standard, the court aligns failure-to-protect and medical-indifference claims with Farmer’s criminal-law recklessness. Allegations sounding in negligence, resource constraints, or disagreements with medical judgment will not suffice.
Short-term segregation rarely suffices under Sandin without comparative detail: Brief administrative segregation—without allegations of sentence impact or sharply atypical conditions compared to general population—will generally not support a procedural due process claim.
Transfers remain non-cognizable under due process: Meachum continues to foreclose liberty-interest claims based purely on intrastate transfers. Prisoners challenging transfers must look to other constitutional hooks (e.g., properly pleaded First Amendment retaliation), which were not before the court here.
Structuring inmate-on-inmate theft claims: Framing financial loss due to other inmates’ actions as an Eighth Amendment failure-to-protect theory is unlikely to succeed absent facts tying the loss to health or safety and the defendants’ subjective knowledge. Alternative theories would require state action and due process parameters not present in this record.
Appellate preservation: The opinion is a reminder that new claims should not be saved for appeal. Litigants must present their theories in the district court—especially when amendment opportunities are circumscribed.

Complex Concepts Simplified

Section 1983: A vehicle to sue state actors for violations of federal rights. You must show (1) a deprivation of a federal right; (2) by someone acting under color of state law; and (3) a causal link between the official’s acts and the harm.
Deliberate Indifference (Eighth Amendment): Not mere carelessness. It is “subjective recklessness”—the official actually knew of a serious risk to the prisoner and ignored it, and did not respond reasonably under the circumstances.
Failure to Protect: Prison officials must take reasonable steps to protect inmates from known, substantial risks of violence. General fear or a dangerous environment is not enough; there must be knowledge of a specific risk and a feasible opportunity to act.
Serious Medical Need: A condition diagnosed as requiring treatment or so obvious even a layperson would know a doctor’s attention is needed, and that, if untreated, risks serious harm.
Administrative Segregation vs. Due Process: Short stints in segregation do not automatically trigger due process protections. A liberty interest exists only if the segregation extends the sentence or imposes atypical and significant hardship compared to ordinary prison life.
Prison Transfers: The Constitution generally does not guarantee confinement in a particular facility. Transfers within a state’s system typically do not create a protected liberty interest.
Pleading Standards (Twombly/Iqbal): Complaints must include enough factual detail to make liability plausible, not just possible. Conclusory statements or legal labels do not suffice.
Forfeiture on Appeal: Arguments not presented to the district court are ordinarily lost and will not be considered for the first time on appeal.

Conclusion

The Eleventh Circuit’s unpublished decision in Beaubrun v. Dodge State Prison affirms the dismissal of a pro se prisoner’s § 1983 complaint for failure to state a claim. The court’s analysis—anchored in Farmer, Wade, Estelle, Sandin, and Meachum—reiterates that Eighth Amendment liability requires subjective recklessness and that reasonable responses shield officials from liability even when harm occurs. It likewise confirms that short, unelaborated stretches of administrative segregation and routine intrastate transfers rarely implicate procedural due process.

Beyond its doctrinal reinforcement, the opinion carries practical guidance for prisoner litigants and counsel: plead concrete facts showing who knew what, when, and how they could have reasonably responded; provide injury details supporting objective seriousness; and, for due process claims, allege either sentence impact or clearly atypical conditions relative to ordinary prison life. Finally, preserve all theories in the district court—new constitutional claims will not be entertained for the first time on appeal.