Barker v. Goodrich
2011 U.S. App. LEXIS 16411
| 6th Cir. | 2011Background
- Barker failed to stand during the 4:00 p.m. count and was escorted to an observation cell in handcuffs, remaining there for over twelve hours with hands restrained behind his back.
- Barker, who was being treated for depression, had his medication and sleep treated as factors in the count discipline.
- Barker alleges he was denied water and restroom access, forced to maintain an uncomfortable position, and his requests for mental health services went unanswered.
- An officer removed Barker’s cuffs only the next morning; no one offered to remove handcuffs or provide water, food, or sanitation during the observation period.
- The district court granted summary judgment on qualified immunity to all defendants, which Barker appeals, arguing violations of his Eighth Amendment rights.
- The court reviews the district court’s summary judgment de novo and applies a two-prong qualified-immunity analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether LCI is entitled to immunity or waived immunity defenses | Barker argues LCI violated his rights and is not shielded by immunity | LCI/Defendants contend immunity (sovereign or qualified) applies | LCI not immune; district court reversed on this issue |
| Whether monetary damages against defendants in official capacities are barred by Eleventh Amendment | Monetary claims against officials in official capacity proceed | Eleventh Amendment bars official-capacity monetary damages | Yes; monetary damages against official-capacity defendants barred; declaratory/injunctive relief may proceed |
| Whether the defendants violated Barker’s Eighth Amendment rights and if qualified immunity applies | There was a deliberate indifference and cruel confinement; rights clearly established | No violation or not clearly established | Constitutional violation proven; right clearly established; qualified-immunity defense reversed in part; remand for proceedings |
Key Cases Cited
- Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (unnecessary and wanton punishment; water/standing deprivation)
- Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974) (prolonged restraints/standing conditions violate Eighth Amendment)
- Dellis v. Corr. Corp. of Am., 257 F.3d 508 (6th Cir. 2001) (limited access to water for extended period violates Eighth Amendment)
- Johnson v. Lewis, 217 F.3d 726 (9th Cir. 2000) (limited access to food/water for extended period)
- Ort v. White, 813 F.2d 318 (11th Cir. 1987) (short denial of water can violate Eighth Amendment)
- Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (inadequate prison conditions may violate Eighth Amendment)
- Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established standard for qualified immunity)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for confinement claims)
- Will v. Mich. Dep't of State Police, 491 U.S. 58 (U.S. 1989) (official-capacity suits and Eleventh Amendment implications)
- Kentucky v. Graham, 473 U.S. 159 (U.S. 1985) (sovereign/Eleventh Amendment analysis in local government)