# Patterson

> District Court, M.D. Alabama · August 11, 2026

URL: https://www.frixlaw.com/law-library/cases/11415505

## Case

- **Full name:** Stephen Patterson v. Jimmie L. Brayboy, et al.
- **Court:** District Court, M.D. Alabama
- **Decided:** August 11, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

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## Opinion text

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF ALABAMA
NORTHERN DIVISION

STEPHEN PATTERSON, )
)
Plaintiff, )
)
v. ) CASE NO. 2:26-cv-212-RAH
)
JIMMIE L. BRAYBOY, et al., )
)
Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiff filed this 42 U.S.C. § 1983 action to allege certain violations of his
civil rights, and the Court has now screened the Complaint under 28 U.S.C.
§§ 1915(e)(2)(B) and 1915A.1 Upon review, and for the reasons explained below,
the Court will dismiss two of the named defendants and serve the Complaint upon
the remaining three.
The Complaint alleges that, while incarcerated at Easterling Correctional
Facility on June 2, 2024, Plaintiff was threatened by a mob of inmates. (Doc. 1-1 at
1.) Plaintiff sought help from Defendant Brayboy, but Defendant Brayboy did not
want to help him. (Id.) Plaintiff then showed Defendant Brayboy a knife he kept on
his person “to protect [himself] with,” and Defendant Brayboy ordered Plaintiff to
give him the knife. (Id.) Plaintiff, frustrated that Defendant Brayboy “continued to
disregard [his] problem,” “went bababas” and refused to turn over the knife. (Id.)
The two “had a Mexican standoff for about three to four hours” until Plaintiff “got
very stressed and gave in.” (Id.) At that point, “instead of handcuffing [Plaintiff] and

1 Under these statutes, the Court is required to dismiss a complaint or any portion thereof if it is
frivolous or malicious, fails to state a claim for which relief may be granted, or seeks monetary
relief from a defendant who is immune from such relief.
locking [him] up,” Defendants Brayboy, Thompson, and Love started “beating
[Plaintiff] up.” (Id. at 1–2.) They broke his fingers, busted his head, and “basically
just beat on [him] for a good five-six minutes.” (Id.) Based on these allegations,
Plaintiff brings suit against the above three Defendants as well as Warden Antonio
McClain for “allow[ing] his officers to have a Mexican standoff with [Plaintiff]” and
former Alabama Department of Corrections Commissioner John Hamm for “not
put[ting] in measures” to protect Plaintiff.2 (Id. at 2.)
Plaintiff has failed to state a viable failure to protect claim against either
Defendant McClain or Defendant Hamm. A prison official’s “deliberate[]
indifferen[ce] to a substantial risk of serious harm to an inmate who suffers injury”
gives rise to an Eighth Amendment violation. Marbury v. Warden III, 180 F.4th
1349, 1356 (11th Cir. 2026) (quoting Lane v. Philbin, 835 F.3d 1302, 1307 (11th
Cir. 2016)). “To establish a § 1983 claim for deliberate indifference, a plaintiff must
show ‘(1) a substantial risk of serious harm; (2) the defendants’ deliberate
indifference to that risk; and (3) causation.’” Marbury, 180 F.4th at 1356 (quoting
Marbury v. Warden, 936 F.3d 1227, 1233 (11th Cir. 2019)). To establish deliberate
indifference, a plaintiff must demonstrate “that the defendant acted with ‘subjective
recklessness as used in the criminal law,’ … and to do so he must show that the
defendant was actually, subjectively aware that his own conduct caused a substantial
risk of serious harm to the plaintiff.” Wade v. McDade, 106 F.4th 1251, 1262 (11th
Cir. 2024) (internal citation omitted).3 The Complaint fails to assert any allegations

2 Although they are not named in the caption of the Complaint, the body of the Complaint also
seeks to name “the depity Warden” and Deputy Commissioner Wendy Williams for their failure
to assist in protecting Plaintiff. (See doc. 1-1 at 2.) Plaintiff’s claims against these individuals fail
for the same reasons as Defendants McClain and Hamm.

3 “[C]ivil law generally calls a person reckless who acts or (if the person has a duty to act) fails to
act in the face of an unjustifiably high risk of harm that is either known or so obvious that it should
be known.” Wade, 106 F.4th at 1256 (citing Farmer v. Brennan, 511 U.S. 825, 836 (1994)). By
sufficient to demonstrate that Defendants McClain and Hamm acted with subjective
recklessness as used in the criminal law, see Wade, 106 F.4th at 1262, or were the
cause of Plaintiff’s injuries.
Additionally, to the extent Plaintiff seeks to hold Defendants McClain and
Hamm responsible for the actions of their subordinates under a theory of supervisory
liability, he cannot do so. See Keith v. DeKalb Cnty., Georgia, 749 F.3d 1034, 1047
(11th Cir. 2014) (“[S]upervisory officials are not liable under § 1983 for the
unconstitutional acts of their subordinates on the basis of respondeat superior or
vicarious liability.”); Case v. Riley, 270 F. App’x 908, 911 (11th Cir. 2008)
(“[C]laims against supervisory personnel who did not personally participate in the
acts complained of are not actionable under section 1983.”). Rather, to state a viable
§ 1983 claim against a defendant in his role as a supervisor, a plaintiff must
demonstrate either (1) the supervisor’s personal participation in the unconstitutional
conduct or (2) a causal connection between the supervisor’s actions and the alleged
constitutional violation. Magwood v. Sec’y, Fla. Dep’t of Corr., 652 F. App’x 841,
844 (11th Cir. 2016) (citing Brown v. Crawford, 906 F.2d 667, 671 (11th Cir. 1990)).
The Complaint fails to state allegations sufficient to make either of these showings.
Thus, Plaintiff’s claims against these defendants are due to be dismissed for failure
to state a claim under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A.
Accordingly, it is ORDERED as follows:
(1) Plaintiff’s claims against Defendants Antonio McClain and John
Hamm are DISMISSED without prejudice for failure to state a claim on which relief
may be granted, and the Clerk of Court is DIRECTED to terminate these defendants
from the electronic docket.
(2) The Clerk of Court is further DIRECTED to (a) send a copy of this

contrast, “criminal law … generally permits a finding of recklessness only when a person
disregards a risk of harm of which he is aware.” Id. (citing Farmer, 511 U.S. at 836–37).
Order to the Plaintiff and (b) serve a copy of this Order and the Summons and
Complaint via certified mail on each of the remaining Defendants.
(3) It is the Plaintiff’s responsibility to provide the Clerk’s Office with an
accurate address for each Defendant. Without an accurate address, service of process
cannot be perfected. It is also the Plaintiff’s responsibility to monitor proceedings
and make sure that service has been completed. Except in very unusual
circumstances, a person not properly served will not be deemed a party to this case.
(4) If a service recipient will not accept service for a named Defendant, the
service recipient is DIRECTED to so advise the Court and provide the Court with
the Defendant’s last known address and phone number. This information may be
filed with the Clerk of Court in response to this Order and may be filed under seal.
(5) Defendants Brayboy, Thompson, and Love are ordered to answer or
otherwise respond by motion, in accordance with Rule 12 of the Federal Rules of
Civil Procedure, within 21 days of being served.
Finally, this Order provides notice that the Court has discontinued the
use of the special report process in cases brought by pro se inmates under 42
U.S.C. § 1983. In its place, the Court has adopted an Initial Scheduling Order,
which sets deadlines and governs discovery in accordance with the Federal
Rules of Civil Procedure. This change is intended to streamline case
management, promote uniformity, and ensure consistency with federal
procedural standards. All parties are expected to comply fully with the
obligations established in the Initial Scheduling Order, which will be entered
after the filing of the Defendants’ answer(s).
DONE, on this the 11th day of August 2026.

R. hn JR.
CHIEF UNITED STATES DISTRICT JUDGE

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11415505. Public record. Not legal advice.