September - 2020

Georgia Court of Appeals Reaffirms Need for Compliance with Minimums of Ante Litem Notice

A20A1011. PICKLESIMER et al. v. CITY OF EATONTON et al The Georgia Court of Appeals recently reiterated the need for compliance with the notice provisions of the ante litem notice provisions for a tort claim against a municipality. Brian and Jennifer Picklesimer sued the City of Eatonton and its public works superintendent for injuries Jennifer sustained when the Picklesimers’ vehicle ran off the road. They also sought damages for Brian loss of consortium. The trial court di

Any-Crime Rule Does Not Apply to Malicious Prosecution

The Eleventh Circuit has resolved the issue of whether the any-crime rule applies to malicious prosecution. In Williams v. Aguirre, 965 F.3d 1147 (11th Cir. 2020), two police officers appealed the denial of summary judgment. The officers contended they were entitled to qualified immunity for the plaintiff’s claims, in part, because they had probable cause to arrest the plaintiff for carrying a concealed weapon. In April 2014, the plaintiff, Williams, and another individual, B

Eleventh Circuit Finds Jail Supervisors Entitled to Qualified Immunity Following Death of an Inmate

Following the death of pretrial detainee Kenneth Grochowski at the hands of his cellmate, William Alexander Brooks, Grochowski's surviving adult children initiated an action against Clayton County, Georgia (the “County”) and against four supervisors at the Clayton County Jail (the “Jail Supervisors”). Grochowski v. Clayton Cty., Georgia through Turner, 961 F.3d 1311, 1314 (11th Cir. 2020). Brooks and Grochowski were both arrested on non-violent charges. Neither man had a hi

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