Robert Morgan begged the state to protect him in the chronically overcrowded Kentucky State Reformatory, where other inmates had put a $1,000 price on his head.

“I am writing because I’m in a state prison that is being run by the inmates and the conditions in which I live are very unsafe,” he wrote in a May 2016 letter to former Corrections commissioner Rodney Ballard and to Gov. Matt Bevin.

Two months later, Warden Aaron Smith announced plans to close five dorms at the 79-year-old reformatory in La Grange and move half the inmates elsewhere.

But on Sept. 11, 2016, with the prison still over its capacity, inmates chased Morgan through the prison yard and to his cell, where he was beaten and stabbed 17 times. He suffered a concussion and a collapsed lung, as well as permanent injuries.

In a lawsuit filed Monday in U.S. District Court, Morgan and another inmate who was beaten into unconsciousness five days earlier charge they were both victims of dangerous prison under-staffing.

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The suit says both corrections officers and inmates live and work in a chaotic environment where “violent inmates prey on vulnerable and isolated” prisoners and “collect debts or dish out prison discipline with vicious assaults.”

Corrections Department spokeswoman Lisa Lamb had no comment on the suit. She said the department was unable to close the dorms or move inmates out of the reformatory because the inmate population continued to grow. She said the department has been "able to maintain security through modified shift schedules," which included mandatory 12-hour, 5 day work weeks, using probation and parole officers for security on their off days and mandatory use of staff from other prisons.

Morgan, 37, of Louisville, has been incarcerated since 1998 and is serving 25 years for burglary, theft and possession of a controlled substance.

The suit was filed by Morgan and a second plaintiff, Leonard Andrew, 50, who allegedly was stomped by other inmates in the yard and lay there for several minutes before anyone noticed. Andrew was sentenced in 2013 in Trimble County to three years in prison on charges of wanton endangerment and escape. He suffered a permanent eye injury, the suit says.

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Filed by Louisville attorneys Aaron Bentley and Michele Henry, the complaint says their clients would not have been assaulted nor injured so severely if “defendants had not been deliberately indifferent.”

The U.S. Supreme Court held in 1994 that a prison official’s "deliberate indifference" to a substantial risk of harm to an inmate violates the Eighth Amendment’s ban on cruel and unusual punishment. The ruling came in a case in which a transgender woman placed in the male population at the U.S. Penitentiary at Terre Haute, Indiana, was repeatedly raped, beaten and infected with HIV.

In addition to Smith, the lawsuit names as defendants the state, Justice and Public Safety Secretary John Tilley, acting Corrections Commissioner James Erwin, reformatory psychologist Julie Barber, and five officers: Carlton Jobe, Alvin Brown, Danny Acosta, Darrell Bratton and one identified only as Jones.

State records show that the reformatory held 1,773 inmates the week of Morgan's assault, 82 over its operational capacity.

Bentley provided the Courier-Journal a copy of Morgan’s eight-page handwritten letter, which the prison system's ombudsman acknowledged receiving.

“Inmates are brewing and drinking homemade alcohol, beating on weaker inmates,” the letter said. “They are preying on sex offenders, extorting them, sexually violating and robbing them. … Inmates are forming gangs and committing serious offenses.”

Two days before he was assaulted, according to the suit, Morgan met with the warden and told him he was afraid for his safety and feared reformatory staff would not protect him. The suit says he was right: “During the lengthy chase and assault, no defendant, nor any other KSR official, intervened to protect Morgan."

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A Corrections Department document provided by Bentley confirms Morgan was targeted for a hit and was stabbed by as many as five inmates. The department’s Classification Committee later voted to put him in permanent protective custody at the Kentucky State Penitentiary in Eddyville.

Bentley said Andrew believes he was assaulted based on a false claim that he had reported inmates for making hooch. The suit doesn't say why Morgan was targeted by other inmates and Bentley said he doesn't know.

Morgan and Andrew ask for compensatory and punitive damages. The lawsuit is assigned to Chief U.S. District Court Judge Joseph H. McKinley Jr.

Corrections records show the reformatory this week holds 1,680 inmates, or 99.3 percent of capacity.

Reporter Andrew Wolfson can be reached at 502-582-7189 or awolfson@courier-journal.com

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