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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 history of violent felonies and neither reported any mental health issues during their intake classification. As such, both men were classified as medium-security inmates and were assigned to the same cell. On August 14, 2012, Brooks and Grochowski got into a fight in their cell over a piece of candy. Grochowski ultimately died due to the injuries sustained during the fight. Plaintiffs argued that the Jail classification process was flawed; the Jail design did not allow the inmates to be monitored; and the Jail was understaffed, which led to infrequent rounds. The Jail Supervisors and the County together moved for summary judgment, arguing that the Jail Supervisors were entitled to qualified immunity.

During the Jail's classification process, a corrections officer determines whether the inmate should be placed in minimum-, medium-, or maximum-security housing based on objective criteria, such as the inmate's current charges, history of violent felony convictions, and any disciplinary records from previous detentions at the Jail. As such, the Court found that Plaintiffs failed to show that the Jail's classification system does not adequately consider an inmate's capacity for violence.

Each cell at the Jail has a solid door with a small window. From the central control towers, officers have a clear view into each pod, but do not have a clear view into each cell. Officers do have a complete view of a cell's interior when they look through the cell door's window from two or three feet away. Each cell is also equipped with an emergency call button, which enables inmates to send an emergency signal to officers in the control tower. The Court found that the emergency call button and the Jail’s classification process mitigate the risk of undetected in-cell assaults. As such, the Jail's design was not constitutionally deficient.

Each housing unit at the Jail is staffed with two officers: one guard in the control tower and one on the floor. Officers conduct physical cell checks every hour and conduct a headcount three times per day. The Court found that the Jail’s practice of hourly rounds does not pose a substantial risk of serious harm to inmates at the Jail. See also Popham v. City of Talladega, 908 F.2d 1561, 1565 (11th Cir. 1990) (holding that jail officials were entitled to qualified immunity because the plaintiff “cite[d] no cases for the proposition that deliberate indifference is demonstrated if prisoners are not seen by jailers at all times”). Accordingly, the Court affirmed the grant of the Jail Supervisors’ and the County’s motion for summary judgment.

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