Background
Mitchell Marbury, an inmate at St. Clair Correctional Facility in Alabama, alleged that prison officials were deliberately indifferent to a substantial risk of serious harm from inmate-on-inmate violence. After a 2016 attack, Marbury was transferred but returned to the facility in 2017. In 2018, he was struck with a dumbbell by another inmate. Marbury filed a Section nineteen eighty-three claim alleging a generalized risk of violence pervaded the prison. The district court granted summary judgment for the officials, finding Marbury failed to show a substantial risk of serious harm. The Eleventh Circuit previously vacated a dismissal in this case to allow discovery, which revealed 112 assaults in 2016 and 84 in 2017.
The court’s reasoning
The court held that Marbury provided sufficient context for his statistical allegations by showing the total prison population and the time period of the assaults, which indicated an average of one assault for every ten inmates. The court found these numbers dwarfed those deemed insufficient in prior precedent. Additionally, Marbury’s sworn pleadings identified specific features of the facility, including unauthorized inmate movement and the availability of weapons, which were supported by incident reports. The court declined to address qualified immunity or other elements of the claim because the district court had not ruled on them.
We hold that Marbury has provided the requisite context to support his statistical allegations.
USCA11 Case: 24-13513 Document: 44-1 Date Filed: 07/07/2026 Page: 14 of 22
What it means going forward
The decision requires district courts to carefully contextualize violence statistics and accept sworn allegations of specific facility features when evaluating summary judgment motions in generalized risk of violence cases.