The Seventh Circuit Court of Appeals has issued a decision in a case involving alleged failures by federal prison officials to protect an inmate from violent attacks by his cellmate at the Federal Correctional Complex in Terre Haute, Indiana.
Derek Thomas, who served part of his criminal sentence at the facility, filed suit against multiple prison officials under *Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics* (1971). Thomas alleged that he was repeatedly attacked by his cellmate and suffered serious injuries while housed at the federal facility.
The case, *Derek Thomas v. Jacqueline Carmichael, et al.*, was decided January 23, 2026, following oral arguments heard May 28, 2025. The three-judge panel consisted of Circuit Judges Ripple, St. Eve, and Kolar, with Judge Kolar writing the opinion.
According to court documents, Thomas brought two distinct sets of claims against the prison officials. First, he alleged that two officials violated the Eighth Amendment by failing to protect him from his cellmate's attacks. Second, he claimed all defendants violated the Eighth Amendment by acting with deliberate indifference to his serious medical needs following the attacks.
The case originated in the U.S. District Court for the Southern District of Indiana, Terre Haute Division, where Chief Judge James R. Sweeney II presided. The district court granted summary judgment in favor of the defendants, prompting Thomas to appeal to the Seventh Circuit.
In its opinion, the appeals court acknowledged the disturbing nature of the allegations. "The facts of this case are disturbing," Judge Kolar wrote. "We take Thomas at his word—and the evidence certainly seems to suggest—that he was brutally attacked. And perhaps corrections officials could have done more to protect Thomas."
However, the court noted that the case presented narrow legal questions rather than factual disputes about whether attacks occurred or whether officials could have prevented them. The court identified two primary issues for consideration: whether Thomas presented a claim previously recognized under *Bivens* or subsequent cases that expanded *Bivens* liability, and whether Thomas could defeat the defendants' qualified immunity defense.
The *Bivens* doctrine, established by the Supreme Court in 1971, allows federal prisoners to sue federal officials for constitutional violations in certain limited circumstances. The doctrine has been narrowly construed by courts in recent years, with the Supreme Court expressing reluctance to expand its application to new contexts.
Prison conditions and inmate safety cases involving federal facilities typically proceed under *Bivens* rather than Section 1983, which applies to state and local officials. Federal prisoners seeking to hold prison staff accountable for constitutional violations must navigate the complex requirements of *Bivens* jurisprudence.
The Eighth Amendment's prohibition against cruel and unusual punishment has been interpreted to require prison officials to provide adequate protection for inmates and appropriate medical care. However, courts apply different standards for failure-to-protect claims versus medical care claims, both requiring proof of deliberate indifference by officials.
Qualified immunity protects government officials from liability unless they violate clearly established constitutional rights that a reasonable official would have known about. This defense has become increasingly significant in federal civil rights litigation, often serving as a barrier to claims against prison officials.
The case highlights ongoing challenges in federal prison oversight and inmate safety. The Federal Bureau of Prisons operates facilities across the country, including the Terre Haute complex, which houses both medium and high-security inmates along with the federal death row.
Inmate-on-inmate violence remains a persistent issue in correctional facilities nationwide. Prison officials must balance security concerns, resource limitations, and constitutional obligations to protect inmates from harm. When violence occurs, questions often arise about whether officials acted appropriately to prevent attacks or respond to their aftermath.
The Seventh Circuit's decision adds to the body of case law governing federal prisoner civil rights claims. Circuit courts have taken varying approaches to *Bivens* claims in the prison context, particularly as the Supreme Court has signaled increased skepticism about expanding the doctrine to new situations.
For federal prisoners seeking to challenge their treatment or conditions of confinement, the decision may influence litigation strategies and expectations. The narrow scope of *Bivens* liability and the availability of qualified immunity defense continue to shape the landscape for such claims.
The case also reflects broader debates about accountability in federal corrections. As the federal prison population has grown, so too have concerns about conditions, safety, and oversight within Bureau of Prisons facilities.
While the court's opinion acknowledged the serious nature of Thomas's allegations, the legal framework governing such claims requires careful analysis of established precedent and clearly defined constitutional violations. The intersectionof *Bivens* doctrine, Eighth Amendment requirements, and qualified immunity creates a complex legal environment for federal prisoner civil rights cases.
The decision represents the latest development in ongoing efforts to define the scope of federal official liability for prison conditions and inmate safety, with implications for similar cases throughout the federal system.