By Cliff McCollum
al.com
ELMORE COUNTY, Ala. — The Alabama Supreme Court has protected a Staton Correctional Facility officer from a lawsuit filed by an inmate who was stabbed after two prisoners entered his dorm.
The unanimous result came despite evidence that the officer was working alone in a dorm that materials submitted to the court indicated should have four officers to properly supervise it.
Antavis Dewayne Thornton was stabbed in the back at Staton on May 12, 2022, after two inmates from another dorm entered F Dorm during an evening meal call, according to the court’s Oct. 2 opinion.
Thornton was serving a 30-year prison sentence stemming from a 2016 Tallapoosa County case in which he was convicted of two counts of sodomy, sexual abuse of a child younger than 12 and rape.
Corey Wallace, the correctional officer assigned to the dorm, was responsible that day for both patrolling the housing area and operating the control cubicle that opened and closed the dormitory doors.
Because of staffing shortages, Wallace was the only officer assigned to the dorm and had to perform both jobs at once.
According to the opinion, Wallace called inmates to chow and used the control cubicle to open the dormitory doors.
Shortly afterward, two inmates from another dorm entered F Dorm and began threatening Thornton. One stabbed him in the back.
Thornton made his way to the control cubicle and told Wallace he had been stabbed.
Wallace immediately radioed for assistance.
Thornton was taken to the prison health care unit, where he received staples and sutures, and was later transferred to another correctional facility.
Thornton later sued Wallace individually in Montgomery Circuit Court, alleging that the officer negligently or otherwise wrongfully allowed the inmates to enter the dorm.
He argued Wallace failed to adequately patrol F Dorm and failed to inspect the color-coded armbands used to identify where inmates were assigned.
Wallace sought summary judgment, arguing he was protected by state agent immunity because he was performing his duties as a correctional officer.
After the Montgomery Circuit Court denied his request, Wallace asked the Alabama Supreme Court to intervene.
The justices sided with Wallace.
Much of the case turned on just how specific Staton’s operating procedures were.
The prison’s procedures instructed roving officers to continuously patrol their dormitories, conduct security checks at irregular 30-minute intervals and continue their patrol responsibilities even when they were also required to operate the control cubicle.
Another procedure required correctional officers to visually inspect inmate armbands to make sure prisoners did not enter unauthorized dormitories.
Thornton argued the rules were specific enough that Wallace went beyond his authority if he failed to follow them.
The Supreme Court disagreed.
The court found the procedures established Wallace’s responsibilities but did not dictate exactly how and when he had to perform each one while handling multiple jobs.
That left Wallace some discretion in how to do his job and meant the rules were not detailed enough to strip him of state agent immunity, the court found.
The justices also concluded that even if the rules had been sufficiently specific, Thornton had not presented enough evidence that Wallace violated them.
Thornton testified that he saw Wallace inside the control cubicle repeatedly during his shift and said Wallace remained there with his back to the open doorway after chow was called.
But Thornton also acknowledged that he was not continuously watching Wallace.
Wallace testified that he stood outside the cubicle and walked around after calling chow before returning to the control area to perform his other duties. The court concluded Thornton had not produced enough evidence to rebut that testimony.
Wallace also testified that the two inmates who attacked Thornton could have been wearing armbands or could have slipped past while he was dealing with someone else.
“I can keep a bunch of them out, but one may slip,” Wallace testified. “There’s a lot of men and one guy patrolling one dorm.”
Thornton also argued that Wallace had been deliberately indifferent to a substantial risk of serious harm, which he said amounted to a violation of the Eighth Amendment and prevented Wallace from claiming state agent immunity.
He pointed to Staton’s history of violence, staffing shortages and overcrowding, as well as incident reports documenting violence between inmates.
The Supreme Court acknowledged that Thornton submitted undisputed evidence of Staton’s documented history of inmate violence before his attack.
The justices did not decide whether those conditions created a substantial risk of serious harm. Instead, they assumed for the purposes of deciding the case that Thornton had met that part of the legal test.
The court found that Thornton still had not shown Wallace acted with deliberate indifference.
The opinion distinguished Wallace’s conduct from previous cases involving correctional officers who were asleep or playing computer games while inmates were attacked. The court said Wallace was performing several assigned duties at once and that Thornton had not shown that he knew of a way to reduce a specific danger and consciously or recklessly refused to act.
The assault came amid broader concerns about violence and staffing inside Staton and Alabama’s prison system.
Less than four months before Thornton was stabbed, Staton inmate Ricky Stewart died after what the Alabama Department of Corrections described at the time as an apparent attack by another prisoner with a weapon.
The U.S. Department of Justice sued Alabama in 2020 over conditions in the state’s prisons, including Staton, alleging the state failed to adequately protect inmates from violence and sexual abuse and failed to provide safe conditions.
In an amended complaint, the Justice Department described Alabama’s prisons for men as critically understaffed. Federal records show Staton had filled about 52 percent of the correctional staffing positions considered necessary for its designed capacity as of Sept. 2020.
Those broader prison conditions were not the issue the Alabama Supreme Court was deciding in Thornton’s case.
The question was whether Wallace himself could be held liable.
The court ruled he could not.
“Officer Wallace has demonstrated that he has a clear legal right to State agent immunity,” the court wrote, directing the Montgomery Circuit Court to enter summary judgment in his favor.
All nine justices agreed Wallace should prevail, although Justices Brady Mendheim and Will Parker wrote separately about portions of the court’s reasoning.
Mendheim agreed with the court’s analysis of state agent immunity but did not join its Eighth Amendment reasoning.
Parker, joined by Justice William Sellers, said the Eighth Amendment question could be resolved more narrowly.
He wrote that general awareness of dangerous prison conditions was not enough to establish deliberate indifference.
Thornton, Parker wrote, had not shown that Wallace knew his own conduct placed Thornton at substantial risk of harm.
“To exhibit deliberate indifference, it is not enough for a correctional officer to be generally aware of dangerous conditions existing within a prison,” Parker wrote.
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