Sixth Circuit Grants Qualified Immunity to Sheriff in Tennessee Prisoner’s Assault Case
Zachery Beck was assaulted at the Hamblen County Jail in October 7, 2016. Beck alleged that while in a four-man cell, a detainee from an adjoining cell grabbed him between the bars and held a shank made of shower tile to his throat. One of his cellmates, Sergio Cisneros, then pulled Beck’s pants down and inserted his finger in Beck’s rectum to search for drugs. Beck was warned to be quiet or he would be killed.
Three days later, Cisneros and other detainees told guards that Beck was stealing from them and they better move him. Beck was moved and was involved in a fight. On October 12, he requested medical care for rectal bleeding from the assault. A physical exam at a hospital revealed a small rectal tear with no active bleeding, a contusion to the neck, and another to the right lower lip. The diagnosis was an assault with anal penetration. Charges were not brought against Cisneros due to lack of evidence.
Beck sued Sheriff Esco Jarnagin and Hamblen County. He alleged the overcrowded jail failed to meet minimum standards set by the Tennessee Corrections Institute (TCI), as evidenced by failures cited in inspection reports dating to 2010. Most of the jail’s problems stemmed from “chronic” overcrowding. It has a maximum capacity of 255, but it housed an average of 365 people in the first half of 2016.
TCI’s 2016 report said overcrowding made the “classification process” of putting detainees on their threat level “impossible to achieve.” The failure was “evident” in 153 detainee-on-detainee incidents between January and July 7, 2016.
The district court denied the defendants’ motions for summary judgment. Jarnigan appealed, asserting he was entitled to qualified immunity. The Sixth Circuit agreed.
The court focused on the “clearly established” rule, which requires prior opinions from it or the United States Supreme Court. That rule, the court wrote, requires “that a plaintiff must identify a case with a similar fact pattern that would have given ‘fair and clear warning to officers’ about what the law requires.” The rule “must be ‘particularized’ to the facts of the case.”
The Sixth Circuit found that “Jarnagin did make some efforts ‘to abate’ the general risk of inmate-on-inmate violence.” From the time he became sheriff, Jarnagin sought and obtained increased funding to hire more guards and he repeatedly told Hamblen County commissioners that they needed to build a new jail.
The court said Beck failed to point to a case that gave Jarnagin a “fair and clear warning” about what the law required “in the situation in which he found himself: a resource-limited official who knew of general safety concerns arising from overcrowded and understaffing problems largely outside his control.
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Related legal case
Beck v. Hamblen Cty.
| Year | 2020 |
|---|---|
| Cite | 969 F.3d 592 (6th Cir. 2020) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Appeals Court Edition | F.3d |