Williams v. Hall

While incarcerated at a private prison in Tennessee, Daniel Williams became the unlucky recipient of attention from a prison gang. After the gang started threatening Mr. Williams, he repeatedly begged for protection. Unfortunately, his pleas were ignored; at one point, staff even told him to stop talking and “go back to his f***ing cell now!” Mr. Williams was right to be concerned for his safety: within a few weeks, a member of the prison gang raped him.

Mr. Williams reported his rape, and that report should have been confidential. But prison staff told the gang that Mr. Williams had “snitched” on them, and the gang took revenge on Mr. Williams—enabled by prison officials.

Guards would unlock Mr. Williams’s cell so that the gang could come in, allowing the gang to hit Mr. Williams in the head, hold him at knifepoint, threaten to kill him, steal his belongings, extort him for money, and throw urine at him. Mr. Williams tried over and over to get protection from prison officials, but was ignored every time. And when he begged one prison official for help, she not only refused to help him, but actually took steps to increase the danger he faced by publicly labeling him as a “snitch.” Worse still, Mr. Williams suffered from severe PTSD following his rape, but when he asked for mental health treatment, prison officials refused.

Mr. Williams tried to sue to vindicate his constitutional rights. But the district court dismissed his case in part because it found that he had not met the Prison Litigation Reform Act’s requirement that he suffer from a “physical injury” or have been the victim of a “sexual act.”

The court also dismissed his case because it found that Mr. Williams—who represented himself pro se in the district court—hadn’t been clear enough about some of his allegations.

We represent Mr. Williams before the U.S. Court of Appeals for the Sixth Circuit. Our briefs explain that Mr. Williams sufficiently showed that he was the victim of a “sexual act” (because he was raped) and that he suffered a “physical injury” (because he was hit in the head), and thus satisfied the Prison Litigation Reform Act’s requirements. And we explain that given the lenient interpretation owed to pro se prisoner plaintiffs, Mr. Williams’s complaint adequately alleged that prison officials failed to protect him, both before and after his rape, and that they unjustly denied him the mental health care he desperately needed.

We’re proud to report that the Sixth Circuit agreed that the district court was wrong to throw out Mr. Williams’s case.

In particular, the Sixth Circuit confirmed that Mr. Williams was the victim of a “sexual act,” so the Prison Litigation Reform Act does not bar his claims. The Sixth Circuit also allowed Mr. Williams to proceed with his claims that the prison failed to provide him the mental health care he needed and that they failed to protect him from being raped. We’re honored to have represented Mr. Williams in his fight to hold the private prison accountable for violating his constitutional rights.