The Eleventh Circuit Grants Qualified Immunity to Officers Responding to an Altercation that did not

Officers of the Georgia Southern University (“GSU”) Division of Public Safety arrested Charles Rankin at a tailgate outside the football stadium for instigating an altercation with a drunken attendee. Rankin filed suit against the officers and the district court ruled that the officers were entitled to qualified immunity. Rankin v. Bd. of Regents of Univ. Sys. of Georgia, 732 Fed. Appx. 779 (11th Cir. 2018). As a result, Rankin appealed. Rankin was a Corporal in the Georgia State Patrol. He took his ten-year-old son to the GSU football game. Although Rankin was off-duty, he notified the GSU Division of Public Safety that he would be in attendance and carrying a firearm. While at the tailgate

The Eleventh Circuit Grants Qualified Immunity to Corrections Officer after Inmate Dies of an Overdo

Sheneque Proctor was in pretrial detention at the Bessemer City jail when she died from a drug overdose. Latunja Johnson, her mother and personal representative, filed a lawsuit against Karrie Goodwin, a jail corrections officer who was on duty while Proctor was in detention. Johnson v. Bessemer, Alabama, City of, 2018 WL 3359672 (11th Cir. 2018). Johnson alleged deliberate indifference to a serious medical need. The district court granted summary judgment to Goodwin on the basis of qualified immunity and Johnson appealed. On November 1, 2014, Bessemer City police received a dispatch call about a disturbance at an Economy Inn motel. Officers arrived at the motel around 1:40 p.m. and found Pr

The Eleventh Circuit Upholds Qualified Immunity for Officers Using Physical Force on a Non-Compliant

Following his arrest for a DUI, Steven Kraus brought claims of excessive-force under 42 U.S.C. § 1983 against Deputy Michael Gargan, Sergeant David Sansone, and Sheriff William Snyder, and state-law battery claims. Kraus v. Martin Cty. Sheriff's Office, 2018 WL 4201201 (11th Cir. 2018). The district court granted summary judgment in favor of each defendant as to all claims. According to Kraus, he had “been drinking and driving [his] whole life,” and it wasn’t until 2012 that he was finally caught and arrested for DUI. While being transported to jail, Kraus repeatedly asked the deputy to shoot him and to use the excuse that Kraus tried to run away. Once at the jail, the deputy reported Kraus’

Prison Wardens Must Not Make “End-of-Life” Medical Decisions without Advance Consent from the Prison

On appeal, Carter Davenport, a prison warden, argued that he was entitled to qualified immunity from claims by the estate of Marquette F. Cummings Jr., a prisoner who was stabbed by a fellow inmate. Estate of Cummings v. Davenport, 2018 WL 4705723 (11th Cir. 2018). After he was stabbed, Cummings was transported to a hospital and died the next day. His estate filed a civil-rights complaint alleging that Davenport violated the Eighth and Fourteenth Amendments to the Constitution by illegally interfering with Cummings's end-of-life medical care with deliberate indifference to his serious medical needs. The district court determined that Davenport failed to establish that his alleged actions, w

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