Ronald J. Hamilton, Jr. v. Superintendent DeAngelo Earl, Ouachita River Correctional Unit (“ORCU”)

United States Court of Appeals
For the Eighth Circuit
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No. 25-1187
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Ronald J. Hamilton, Jr.
lllllllllllllllllllllPlaintiff - Appellant
v.
Superintendent DeAngelo Earl, Ouachita River Correctional Unit (“ORCU”);
Todd Ball, Deputy Warden ORCU; Bryant Dallas, Shift Captain ORCU
lllllllllllllllllllllDefendants - Appellees
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Appeal from United States District Court
for the Western District of Arkansas - Ft. Smith
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Submitted: January 13, 2026
Filed: February 17, 2026
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Before LOKEN, ARNOLD, and GRUENDER, Circuit Judges.
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ARNOLD, Circuit Judge.
While incarcerated in an Arkansas prison, Ronald Hamilton, Jr., spent about
six weeks in isolation without air conditioning in the middle of summer. Hamilton
maintains that his stint in isolation amounted to cruel and unusual punishment under
the Eighth and Fourteenth Amendments because prison officials knew that he, as a
dialysis patient, shouldn’t be exposed to excessive heat, yet they did not move him

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to a cell with air conditioning. The district court1 granted summary judgment to the
prison officials, holding that they were entitled to qualified immunity, and Hamilton
appeals. Reviewing the court’s grant of summary judgment de novo, and viewing the
evidence in a light most favorable to Hamilton, see De Rossitte v. Correct Care Sols.,
LLC, 22 F.4th 796, 802 (8th Cir. 2022), we affirm.
Hamilton was imprisoned in the Ouachita River Unit of the Arkansas
Department of Corrections. One July day Hamilton got into a physical altercation
with a prison guard. After he was evaluated by the prison’s medical staff, prison
officials moved him from an air conditioned cell in the Special Needs Unit to a cell
in an isolation unit that lacked air conditioning. Though we don’t know the precise
temperature inside Hamilton’s cell, he says, without showing how he knew, that the
temperature was just as hot as the outside temperature, which during the relevant time
rose as high as 95 degrees Fahrenheit according to the historical records Hamilton
offers.
Hamilton filed several grievances while housed in isolation. Among these was
one filed four days after his placement there in which he asserted that he should be
moved to the Special Needs Unit because he was on dialysis and had other health
issues. Warden DeAngelo Earl denied the grievance, explaining that no documented
medical restrictions prohibited him from being housed in isolation and that his
previous disciplinary confinements in the Special Needs Unit were for convenience
and not medical necessity.
Hamilton submitted a more elaborated grievance about four weeks into his time
in isolation. In this one Hamilton explained that, though he had access to water, his
dialysis regimen restricted him to drinking no more than a liter of fluid between
1The Honorable Susan O. Hickey, then Chief Judge, now United States District
Judge for the Western District of Arkansas.
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treatments. This restriction, he said, caused him physical discomfort: Because he
perspired excessively in the summer heat, he could not replace the water his body
needed to avoid painful cramping. He also stated that a dialysis nurse had told
Captain Bryant Dallas about Hamilton’s predicament. Earl denied this grievance as
well, telling Hamilton that officials had contacted Dr. Thomas Daniel, a prison
physician, about the situation, and Dr. Daniel had opined that moving Hamilton was
not an emergency. Hamilton submitted another grievance a few days after this second
one, insisting that the dialysis nurse manager and the health services administrator in
the Special Needs Unit had informed Dallas in an email that he needed to move
Hamilton for medical reasons. This grievance met the same fate as the others. In
rejecting it, Earl noted that Deputy Warden Todd Ball had spoken to the health
services administrator and others who said that there was no reason Hamilton
couldn’t be housed in isolation. So about a week later, Hamilton submitted a last
grievance in which he asserted he had informed Ball directly about his plight but that
Ball had done nothing about it. Earl denied this grievance as well for the same reason
he denied the previous one. Five days after he filed that final grievance, Hamilton was
transferred to the Special Needs Unit.
Hamilton sued Earl, Ball, and Dallas under 42 U.S.C. § 1983, claiming that
they had subjected him to cruel and unusual punishment, causing him nerve damage
and later the loss of his kidneys. After the parties completed discovery, the defendants
moved for summary judgment, and a magistrate judge recommended that the district
court deny the motion. The district court, however, declined to adopt the magistrate
judge’s recommendation and instead granted the defendants summary judgment on
the ground that they were entitled to qualified immunity. Hamilton moved
unsuccessfully for the court to reconsider its decision.
Qualified immunity “shields government officials from liability when their
conduct does not violate clearly established constitutional rights of which a
reasonable person would have known.” See Joseph v. Wheeler, 144 F.4th 1111, 1113
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(8th Cir. 2025). To determine whether the defendants are entitled to qualified
immunity, we ask whether they violated a constitutional right and whether that right
was clearly established. See Melton v. City of Forrest City, 147 F.4th 896, 901–02
(8th Cir. 2025). If the answer to either question is no, the defendants are entitled to
qualified immunity. See McDaniel v. Neal, 44 F.4th 1085, 1089 (8th Cir. 2022).
In considering whether the defendants violated Hamilton’s constitutional right
to be free of cruel and unusual punishment, we note at the outset that while the Eighth
and Fourteenth Amendments don’t mandate comfortable prisons, they do prohibit
inhumane ones; and prison officials must ensure that inmates “receive adequate food,
clothing, shelter, and medical care.” See Farmer v. Brennan, 511 U.S. 825, 832
(1994). Since the constitution protects against cruel and unusual “punishments,” and
not cruel and unusual “conditions,” see id. at 837, it protects prisoners only against
“unnecessary and wanton infliction of pain,” which the Supreme Court has said
results from, at a minimum, prison officials’ deliberate indifference. See Wilson v.
Seiter, 501 U.S. 294, 297 (1991).
As the district court observed in its summary-judgment order, Hamilton’s
complaint lacks a certain clarity. He might be challenging the conditions of his
confinement, the unconstitutional denial of medical care, or both. After all, the
medical care an inmate receives is as much of a condition of confinement as “the
temperature he is subjected to in his cell.” See id. at 303. But whatever category
Hamilton’s claim most comfortably belongs in, to prevail he must show that his
predicament was sufficiently serious: He must show that he was incarcerated in
conditions that posed an objectively substantial risk of serious harm, see Kulkay v.
Roy, 847 F.3d 637, 642 (8th Cir. 2017), or that he suffered from an objectively
serious medical need. See Schaub v. VonWald, 638 F.3d 905, 914 (8th Cir. 2011). The
parties dispute whether Hamilton has carried this burden at this stage of the case, but
we will assume that it is objectively serious for a person with a kidney disease
requiring dialysis to be housed in high temperatures for six weeks given that he is on
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a fluid restriction. Or stated another way, we will assume that air conditioning was
an objectively serious medical need for someone in Hamilton’s circumstances.
To succeed on his claim, though, Hamilton must also demonstrate that the
defendants acted, at a minimum, with deliberate indifference toward him. See Wilson,
501 U.S. at 297. Deliberate indifference is more than mere negligence or the ordinary
lack of due care for a prisoner’s safety. See Letterman v. Does, 789 F.3d 856, 862 (8th
Cir. 2015). It is more even than gross negligence. See Kulkay, 847 F.3d at 643.
Liability requires a showing that the defendants acted with a highly culpable state of
mind that resembles criminal-law recklessness and approaches actual intent. See id.
The evidence must demonstrate that officers understood that a substantial risk of
harm or medical need existed and that they knew their conduct was inappropriate in
light of that risk or need. See Letterman, 789 F.3d at 862.
Even if the three defendants had known, from Hamilton’s grievances or
otherwise, that a substantial risk of harm or a serious medical need existed, the record
lacks sufficient evidence to support a finding that they responded to the risk or need
inappropriately, much less that they knew they had responded inappropriately. First,
Hamilton did not have a documented medical restriction directing that he should not
be exposed to high temperatures. He had such a restriction at one time, but it ended
in 2018 because, according to a note accompanying that restriction’s termination, he
“is now on dialysis—not on medication that would make him sensitive to heat.” It’s
therefore difficult to fault the defendants for concluding that Hamilton could be
housed in a cell without air conditioning.
Hamilton attempts to set up Earl’s own words against him, emphasizing that
a year before he was in isolation Earl wrote in response to an unrelated grievance that
Hamilton was placed in the Special Needs Unit rather than isolation “[d]ue to
[Hamilton’s] medical status.” But Earl did not say that Hamilton’s medical status
required that he be placed in the Special Needs Unit. In fact, when Hamilton appealed
Earl’s decision regarding that grievance, the prison official who responded explained
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that Hamilton was assigned to the Special Needs Unit “instead of isolation due to
your medical needs, which could be addressed easier in” the Special Needs Unit
given the location where Hamilton received dialysis treatments. As Earl himself
would later put it, Hamilton’s medical status merely made the Special Needs Unit
more convenient than isolation. And though Hamilton presented evidence that at
different times a few other inmates on dialysis were sent to the Special Needs Unit
when being punished, that doesn’t mean medical necessity, as opposed to
convenience, was the reason. So given the context, we do not think Earl’s remark a
year earlier advances Hamilton’s claim.
In addition, rather than rely on their own assessment of Hamilton’s medical
predicament, jail officials sent a copy of Hamilton’s grievance in which he discussed
his fluid-intake restriction to Dr. Daniel for his opinion, and Dr. Daniel responded
that moving Hamilton was not “an emergency move.” Hamilton’s medical records
also reflect that Dr. Daniel saw Hamilton the same day. Though Dr. Daniel
acknowledged that Hamilton “would be better served” in the Special Needs Unit, he
explained that was because the heat might cause dermatitis to “compromise his
fistula.” Most notably, Dr. Daniel didn’t express any concern about dehydration
despite receiving Hamilton’s specific complaints about it. The defendants, lacking
medical expertise, cannot be said to have been deliberately indifferent when they
sought and received a doctor’s guidance and then didn’t act in any way contrary to
it. See Reece v. Hale, 58 F.4th 1027, 1033 (8th Cir. 2023). And even though Hamilton
questions Dr. Daniel’s judgment, nothing in the record suggests that the defendants
should have done so. Cf. id. (discussing McRaven v. Sanders, 577 F.3d 974 (8th Cir.
2009)).
Hamilton testified that two dialysis nurses told Dallas that Hamilton needed to
be moved from isolation to the Special Needs Unit but that he heard Dallas tell them
“to mind their own business.” The defendants say that we should disregard Dallas’s
alleged conversation with the nurses as hearsay. Dallas’s statement is not hearsay, but
in any case it doesn’t reflect deliberate indifference on Dallas’s part in this context.
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As we said, prison officials contacted a doctor about Hamilton’s complaints who
advised, after examining Hamilton, that there was no emergency. The defendants
simply aren’t deliberately indifferent for taking the doctor at his word, even if medical
personnel who were not physicians had a different opinion.
Still other circumstances evidence a lack of deliberate indifference. While in
isolation, Hamilton occasionally complained about physical ailments, and it appears
that his complaints were promptly addressed. For example, Hamilton complained
more than once about rashes, and he was prescribed different treatments on the very
days in which he complained. He also admitted that he didn’t miss a dialysis
treatment, which he received three times per week. In sum, Hamilton wasn’t thrown
in isolation and forgotten about; he was monitored and was responded to when he had
medical needs and voiced physical discomfort. See De Rossitte, 22 F.4th at 803.
Finally, we observe that the prison implemented measures to mitigate the
effects of the summer heat. Prison officials installed and ran portable air conditioners
in the isolation units. They also kept doors open to the main hall that was air
conditioned so that cool air could circulate into the isolation units. Hamilton disputes
that these measures were effective in lowering the temperature. But he doesn’t dispute
that prison officials undertook them or argue that they knew or even suspected that
they would be futile. Genuine attempts to mitigate Hamilton’s difficulties, even if
ineffective, suggest that prison officials were not deliberately indifferent to
Hamilton’s situation.
For all these reasons, we conclude that the record does not support a finding
that the defendants were deliberately indifferent to Hamilton’s serious medical needs.
Because Hamilton’s cruel-and-unusual-punishment claim therefore fails, we agree
with the district court’s decision to grant the defendants summary judgment.
Affirmed.
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