Sixth Circuit Rejects Qualified Immunity Defense by Guards in Wrongful Death Suit
On August 21, 2015, the Sixth Circuit Court of Appeals rejected an appeal filed by jail officials seeking reversal of a district court’s denial of qualified and statutory immunity in a case involving a prisoner’s death.
Carlton L. Benton was a pre-trial detainee at the Lucas County, Ohio jail in May 2004 when he began to suffer seizure-like symptoms. He was seen at a hospital, and as he was being returned to the jail, guards disconnected his medical devices and restraints; that resulted in an altercation in which Benton was struck and pepper sprayed.
When he arrived at the jail, still in restraints, guards allegedly shoved him to the concrete floor, sprayed him with chemicals and placed him in a chokehold until he passed out. The guards, including jailers John E. Gray and Jay M. Schmeltz, failed to inform medical staff of Benton’s injuries. He was pronounced brain dead on June 1, 2004 and removed from life support the next day.
Jail staff, including supervisory personnel, allegedly falsified after-incident reports and advised Benton’s family that he had died due to natural causes. The cover-up was not discovered for almost four years, and the family then filed a federal civil rights suit under 42 U.S.C. § 1983 in Ohio state court. The defendants included Gray, Schmeltz and Sheriff James A. Telb. After the case was removed to federal court, the FBI reviewed the incident and recommended prosecution of the jail employees involved in Benton’s death, who were indicted. The civil case was held in abeyance until the criminal charges were resolved; Gray and Schmeltz were convicted, while Telb was acquitted. [See: PLN, June 2011, p.36; Oct. 2009, p.48].
When the civil case resumed, the defendants filed motions for summary judgment based upon both qualified and state statutory immunity, which were granted by the district court. On appeal, the Sixth Circuit stated, “To determine whether qualified immunity applies, we use a two-step analysis: ‘1) ... we determine whether the allegations give rise to a constitutional violation; and 2) we assess whether the right was clearly established at the time of the incident.’”
The appellate court then examined the excessive force claim, finding the conduct of Gray and Schmeltz “was knowing or purposeful and ‘objectively unreasonable,’ and each used force that ‘amounted to punishment’ of Benton ... both officers violated [his] Fourteenth Amendment rights.” The Court of Appeals held that “these actions reasonably lead us to conclude that Schmeltz violated clearly established law and was ‘on notice that his alleged actions were unconstitutional.’”
The Sixth Circuit also rejected Sheriff Telb’s defense that he had trained and supervised his jailers properly “to avoid the use of excessive force and to ensure that the medical needs of persons in the Sheriff’s custody were met.” Telb not only “had full knowledge of the assault on [ ] Benton, which led to his death, but nonetheless intentionally and deliberately made false statements to federal officials” about the incident.
The case was remanded to the district court for further proceedings, where it remains pending with a trial date scheduled for January 9, 2017. See: Coley v. Lucas County, 799 F.3d 530 (6th Cir. 2015).
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Related legal case
Coley v. Lucas County
| Year | 2015 |
|---|---|
| Cite | 799 F.3d 530 (6th Cir. 2015) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |