Appeals Court Outlines How Steps to Address Understaffing May Counter Deliberate Indifference Claims

The Sixth Circuit’s recent ruling sheds light on federally regulated employers’ options and responsibilities to address understaffing. The appeals court affirmed the dismissal of an Eighth Amendment claim against prison officials after the overdose death of an inmate. The court recognized the prison’s efforts—such as raising salaries, offering bonuses and improving training—as effective ways to demonstrate that officials were not being deliberately indifferent to staffing shortages in their effort to comply with and uphold constitutional protections.

Darius Caraway was serving a life sentence when he overdosed in prison. He was pronounced dead shortly after being transported to a nearby hospital. Caraway’s estate sued prison officials and the private company operating the prison, claiming the defendants violated the Eighth Amendment by failing to protect Caraway from overdosing on fentanyl. The estate maintained that Caraway’s “overdose risk stemmed from . . . understaffing” to which prison officials were deliberately indifferent.  

In affirming a lower court’s dismissal, the Sixth Circuit Court of Appeals held that prison officials responded reasonably to the staffing shortages. The court foreclosed any finding that prison officials violated the Eighth Amendment through deliberate indifference to those shortages. The Sixth Circuit relied on several efforts prison officials took to address the staffing shortages, including:

• Increasing officer salaries
• Offering signing and relocation bonuses
• Reworking the officer training program
• Improving staffing at critical posts
• Using a detailed staff monitoring system

The Sixth Circuit concluded that “[f]ar from showing indifference,” these efforts showed that prison officials “‘acted reasonably’ to address the shortage,” and those officials could not be found to have violated the Eighth Amendment through deliberate indifference to staffing shortages.

Detention and corrections facilities nationwide should continue to consider proactive measures as they combat staffing shortages. Similarly, educational facilities subject to Title IX discrimination and harassment laws should take note of this decision and the efforts highlighted by the court.

This ruling serves as a guidepost for federally regulated industries on the importance of taking proactive steps to address staffing challenges. Even where shortages might persist despite these efforts, this decision provides an example of the types of efforts courts may consider significant when evaluating claims of deliberate indifference.

Please contact Nick Morisani or any member of the Phelps team if you have any questions or need advice or guidance.