The U.S. Court of Appeals for the Eleventh Circuit has affirmed a district court's dismissal of a federal prisoner's civil rights lawsuit against prison officials, rejecting claims of negligent cellmate assignment and excessive force.

David A. Diehl, a federal prisoner representing himself pro se, filed the lawsuit against the United States alleging that prison officials negligently assigned him a dangerous cellmate and that one official battered him by pepper-spraying his cell following an attack by his cellmate. The case, David A. Diehl v. United States of America, was decided by a three-judge panel consisting of Circuit Judges Newsom, Luck, and Lagoa.

The litigation originated in the U.S. District Court for the Middle District of Florida, where Diehl brought claims under the Federal Tort Claims Act (FTCA). The district court's handling of the case involved multiple stages of review, including discovery orders and two dispositive rulings that ultimately resolved the matter in favor of the government.

Regarding the negligent cellmate assignment claim, the Eleventh Circuit found that the district court correctly applied the FTCA's discretionary-function exception, which bars claims against the government for decisions involving policy judgment or choice. The court determined that prison officials' cellmate assignment decisions fall within this protected category of discretionary governmental functions.

For the excessive force claim involving pepper spray use, the appellate court upheld the district court's finding that the force employed was objectively reasonable under Florida law. The court concluded that the prison official's actions in using pepper spray following the cellmate attack did not constitute battery under applicable legal standards.

The decision reinforces established precedent limiting prisoners' ability to pursue federal tort claims against prison officials for housing decisions and use of force incidents that fall within accepted correctional practices. The Eleventh Circuit's ruling demonstrates the high bar prisoners face when challenging prison administrative decisions and staff conduct through federal civil rights litigation.