Cook v. Horsley, 24-10626

Reyce Janon Cook, a Texas inmate, filed a § 1983 action alleging violations of his constitutional rights due to an allegedly unreasonable strip and body cavity search.
The defendants included supervisory prison officials and staff at the facility where the incident occurred.
Cook argued that the search was conducted by officers and cadets without a legitimate penological purpose.
The district court granted summary judgment to the defendants, dismissing Cook's claims.
Cook appealed the summary judgment ruling to the Fifth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Supervisory liability for unconstitutional search	Supervisors knew/approved of search, making them liable	Plaintiff provided no evidence satisfying that standard	No summary judgment evidence shown; no liability
Failure to supervise/train subordinates	Failures amounted to deliberate indifference	Mere failure to supervise/train is insufficient	No deliberate indifference established
Liability based on knowledge/acquiescence	Supervisors knew of cadets’ actions, implying liability	Mere knowledge/acquiescence isn't enough	Knowledge/acquiescence not sufficient
Summary judgment standard	Genuine issue of material fact exists	No genuine dispute over material facts	No genuine material factual dispute

Ashcroft v. Iqbal, 556 U.S. 662 (rejects that supervisors are liable solely for knowledge/acquiescence in subordinates’ violations)
Freeman v. Tex. Dep’t of Crim. Just., 369 F.3d 854 (discusses standards for supervisory liability under § 1983)
Connick v. Thompson, 563 U.S. 51 (sets requirements for deliberate indifference in failure to supervise claims)
Goodman v. Harris County, 571 F.3d 388 (reiterates threshold for failure to train/supervise liability)
Estate of Davis ex rel. McCully v. City of North Richland Hills, 406 F.3d 375 (clarifies deliberate indifference requirement for municipal liability)