Brent Jacoby v. Baldwin County
2016 U.S. App. LEXIS 15929
11th Cir.2016Background
- Plaintiff Brent Jacoby, a pretrial detainee at Baldwin County Corrections Center, was placed in administrative segregation after a positive cocaine test on Aug. 12, 2012.
- Jacoby alleges he was the third occupant of an 8x10 two-man cell, forced to sleep on a mattress on the floor next to a toilet, exposed to human waste, and developed a foot rash.
- On Aug. 15, 2012 Jacoby received a disciplinary hearing for the failed drug test; he was not allowed to call Sergeant Griffith as a witness and Officer Arnold, who escorted him for testing, sat on the three-member hearing board.
- Jacoby sued under 42 U.S.C. § 1983 claiming substantive and procedural due process violations; the District Court granted summary judgment for Sheriff Huey Mack based on qualified immunity; Jacoby appealed.
- The Eleventh Circuit reviewed de novo, applied Bell (pretrial detainee standard) to substantive claims, and Wolff (disciplinary hearing protections) to procedural claims, and assessed qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether confinement conditions in segregation constituted unconstitutional punishment (substantive due process) | Jacoby: overcrowded, unsanitary cell, forced to sleep next to a toilet and exposed to feces — amounts to punishment | Mack: conditions did not clearly violate due process; qualified immunity applies; temporary double- or triple-bunking and mattress-on-floor not clearly unlawful | Court: No clearly established law put Mack on fair notice; Jacoby’s facts not close enough to controlling precedent; qualified immunity affirmed |
| Whether denial of witness (Sergeant Griffith) at disciplinary hearing violated due process (procedural) | Jacoby: refusing key witness prevented meaningful defense | Mack: hearing discretion allows refusal of witnesses when necessary for safety/administration; no requirement to state reasons; qualified immunity | Court: Wolff allows discretion and does not impose a strict burden to justify refusal; no clearly established violation; qualified immunity affirmed |
| Whether Officer Arnold’s participation on the hearing board violated impartiality requirement | Jacoby: Arnold directly involved in investigation (escorted, present at test, placed him in segregation) so board was biased | Mack: Arnold had no decisionmaking role in arrest/investigation; participation permissible; no clear precedent making this unlawful | Court: Under facts alleged, Arnold’s role was not the sort of substantial decisionmaking that clearly disqualified him; no clearly established violation; qualified immunity affirmed |
| Whether pretrial detainees must satisfy Sandin to obtain procedural protections | Jacoby: N/A (argued he was entitled to Wolff protections) | Mack/District Court applied Sandin-like analysis | Held: Bell (not Sandin) governs pretrial detainees; pretrial detainees are entitled to Wolff protections before punishment, but Jacoby still failed to overcome qualified immunity on his specific procedural complaints |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (pretrial detainees may not be punished prior to adjudication; governs substantive due process for detainees)
- Wolff v. McDonnell, 418 U.S. 539 (minimum procedural protections in prison disciplinary hearings)
- Sandin v. Conner, 515 U.S. 472 (test for protected liberty interests for convicted inmates; atypical and significant hardship analysis)
- Hope v. Pelzer, 536 U.S. 730 (clarifies "clearly established" standard for qualified immunity)
- Hamm v. DeKalb County, 774 F.2d 1567 (11th Cir.) (conditions like temporary mattress-on-floor not per se constitutional violations standard discussion)