Christopher Franklin v. Jeffrey Young
2015 U.S. App. LEXIS 10739
| 8th Cir. | 2015Background
- Franklin, an inmate, alleges Young violated the Eighth Amendment by failing to protect him from sexual assault by Mosley.
- Franklin contends Young was deliberately indifferent to a substantial risk of harm to him while incarcerated.
- Young moved for summary judgment on the ground of qualified immunity.
- The district court denied Young’s motion, finding genuine disputes of material fact regarding risk and intent.
- Young appealed interlocutorily, arguing there was no substantial risk or deliberate indifference and that the district court erred.
- The appellate court dismissed the appeal for lack of jurisdiction, as the dispute centers on fact-finding at trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to review qualified-immunity denial | Young argues the appeal seeks review of a pure fact dispute. | Franklin contends the court can review legal questions raised by the denial. | Lacks jurisdiction; review of fact disputes in summary-judgment denial is not allowed on interlocutory appeal. |
| Whether pretrial record sets a genuine issue of material fact | The pretrial record shows a substantial risk and deliberate indifference by Young. | There is no genuine issue of material fact regarding risk or indifference. | Dismissed for lack of jurisdiction; court does not reach disputed-fact questions on interlocutory appeal. |
Key Cases Cited
- Austin v. Long, 779 F.3d 522 (8th Cir. 2015) (interlocutory appeal limits on qualified-immunity review when facts are disputed)
- White v. McKinley, 519 F.3d 806 (8th Cir. 2008) (jurisdictional limits on reviewing summary-judgment orders in qualified-immunity cases)
- Behrens v. Pelletier, 516 U.S. 299 (1996) (summary-judgment-based qualified-immunity questions and final-judgment standards)
- Johnson v. Jones, 515 U.S. 304 (1995) (interlocutory review restrictions on disputes of fact in qualified-immunity appeals)
- Pace v. City of Des Moines, 201 F.3d 1050 (8th Cir. 2000) (recognizes limits on reviewing factual disputes in interlocutory qualified-immunity appeals)