Wingfield v. Garner: Sovereign Immunity Bars Official-Capacity Damages and Intent Requirement for ADA and Eighth Amendment Claims

Introduction

The case of Wingfield v. Garner arose from a pro se civil rights lawsuit brought by Anthony Bernard Wingfield, a below‐the‐knee amputee incarcerated in a Texas state prison. Wingfield alleged that various correctional officers twice confiscated his medically-approved shoes, forcing him to walk barefoot, miss meals, and endure a 38-day delay in his brace-and-limb clinic appointment. He sued under 42 U.S.C. § 1983 (Eighth Amendment), Title II of the Americans with Disabilities Act (ADA), and the Eighth Amendment, seeking money damages. The district court adopted a magistrate judge’s recommendation and dismissed all claims for lack of subject-matter jurisdiction or for failure to state a claim. Wingfield appealed, and on April 8, 2025, a Fifth Circuit panel unanimously affirmed.

Summary of the Judgment

The Fifth Circuit’s per curiam opinion reached three principal holdings:

Official-Capacity Claims: Barred by the Eleventh Amendment. No waiver or valid Ex parte Young exception applied because Wingfield sought only retrospective damages, not injunctive relief.
Eighth Amendment Claims (Individual Capacity): Dismissed under Rule 12(b)(6) for failure to allege an objectively serious deprivation or that officers were subjectively aware of a substantial risk of serious harm.
ADA Claims: (a) Official-capacity claims barred by sovereign immunity except for Fourteenth Amendment violations, which Wingfield did not plead; (b) Individual-capacity claims for damages require proof of intentional discrimination or intent to accommodate, which the complaint failed to allege.

Analysis

Precedents Cited

Ex parte Young (209 U.S. 123 (1908)): Exception to sovereign immunity for prospective relief against state officials.
Alabama v. Pugh (438 U.S. 781 (1978)): State prisons are arms of the state for Eleventh Amendment purposes.
NiGen Biotech, L.L.C. v. Paxton (804 F.3d 389 (5th Cir. 2015)): § 1983 does not abrogate sovereign immunity.
Farmer v. Brennan (511 U.S. 825 (1994)): Two-prong Eighth Amendment deliberate-indifference test (objective seriousness; subjective knowledge and disregard).
Gates v. Cook (376 F.3d 323 (5th Cir. 2004)): Unsanitary conditions can violate Eighth Amendment when risk is substantial and officials are indifferent.
Petzold v. Rostollan (946 F.3d 242 (5th Cir. 2019)): Delay in medical care must produce some harm to state an Eighth Amendment claim.
Siglar v. Hightower (112 F.3d 191 (5th Cir. 1997)): Brief, mild injuries are de minimis under the PLRA.
United States v. Georgia (546 U.S. 151 (2006)): Title II ADA abrogation of sovereign immunity is valid only for conduct that actually violates the Fourteenth Amendment.
Miraglia v. Bd. of Supervisors of La. State Museum (901 F.3d 565 (5th Cir. 2018)): Intentional discrimination is required to recover money damages under Title II ADA.

Legal Reasoning

The court began by addressing subject-matter jurisdiction under Rule 12(b)(1). It held that Eleventh Amendment immunity bars Wingfield’s official-capacity claims under § 1983 and the Eighth Amendment because they are effectively suits against the State of Texas, which has neither waived immunity nor been stripped of it by Congress. The Ex parte Young exception did not apply, as Wingfield sought only retrospective damages.

Turning to the Eighth Amendment, the Fifth Circuit applied the two-prong test from Farmer v. Brennan. Objectively, Wingfield’s allegations—walking barefoot in unsanitary areas, missing meals, and enduring a clinic delay—did not rise to a denial of “the minimal civilized measure of life’s necessities.” Subjectively, he failed to plead that any officer knew of and consciously disregarded a substantial risk of serious harm. His allegations lacked specifics about actual or imminent injury.

Under the PLRA’s physical-injury requirement (42 U.S.C. § 1997e(e)), Wingfield sought “grave psychological, emotional and physical complexities” and discomfort from the delay, but he offered no factual detail tying these to non-de minimis physical injury. The court found those allegations conclusory.

For Title II ADA, the court first confirmed that Congress validly abrogated sovereign immunity only for Fourteenth Amendment violations. Wingfield pleaded neither an equal-protection nor procedural-due-process theory. His individual-capacity ADA claims likewise failed because Fifth Circuit precedent requires a showing of intentional discrimination or deliberate refusal to accommodate, and his pro se complaint alleged only an undifferentiated denial of shoes without any discriminatory intent.

Impact

This decision underscores three durable principles:

Eleventh Amendment Applicability: Official-capacity damage suits under § 1983 and Title II ADA remain barred absent waiver, abrogation tied to Fourteenth Amendment violations, or a proper Ex parte Young claim seeking prospective relief.
Eighth Amendment Rigor: Prisoner plaintiffs must plead both an objectively serious deprivation of basic needs and facts showing prison officials’ subjective awareness and disregard of a substantial risk of serious harm.
Intent Requirement for ADA Damages: In the Fifth Circuit, compensatory damages under Title II require proof of intentional discrimination or refusal to accommodate disability; negligent or indifferent misconduct alone will not suffice.

Complex Concepts Simplified

Eleventh Amendment Immunity: States—and by extension their agencies and officials sued in their official capacity—cannot be sued in federal court for damages unless the state consents or Congress validly strips that immunity.
Ex parte Young Exception: Allows suits against state officials for prospective injunctive relief to stop ongoing violations of federal law, but does not authorize retrospective damage awards against the state.
Eighth Amendment Deliberate Indifference: Combines an “objective” element (a serious harm or risk) with a “subjective” element (officials knew the risk and ignored it).
PLRA Physical Injury Requirement: A prisoner cannot recover for emotional or mental harm unless accompanied by more than a trivial physical injury.
Title II ADA Intent Requirement: In the Fifth Circuit, to get money damages, a disabled person must show intentional discrimination or deliberate refusal to accommodate, not mere negligence or oversight.

Conclusion

Wingfield v. Garner reaffirms the robust protection of state sovereign immunity, the stringent standards for Eighth Amendment deliberate-indifference claims, and the high bar for recovering compensatory damages under Title II of the ADA in the Fifth Circuit. Prisoners alleging misconduct must plead concrete facts demonstrating both serious harm and deliberate indifference, and disabled plaintiffs must allege intentional discrimination to obtain money relief. This decision will guide lower courts in screening § 1983 and ADA complaints at the pleading stage and clarifies the continuing interplay between sovereign immunity, the PLRA, and disability rights in correctional settings.