Don Meadows v. Rockford Housing Authority
2017 U.S. App. LEXIS 11686
| 7th Cir. | 2017Background
- Meadows leased an RHA apartment for $10/month and worked as an RHA building engineer; tenants reported an unknown person living in his unit.
- Metro Enforcement (private security contractor) investigated after RHA officials reported potential subletting; Metro deputies Novay and Hodges were involved.
- After learning an unauthorized occupant (Sockwell) had a key, Meadows changed his deadbolt; RHA officials then instructed Metro that the locks "should be changed for security and safety purposes."
- While Meadows was at the police station reporting a ransacking, Metro (with a locksmith) entered the apartment, removed the lock, searched, and rekeyed it; Meadows returned, scuffled with Novay, and police admonished Novay that lock-changing was not an eviction.
- Meadows sued under 42 U.S.C. § 1983 (Fourth Amendment) and state trespass; district court found Metro employees acted under color of state law but granted summary judgment to Novay and Hodges on qualified immunity grounds; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether private security employees are entitled to qualified immunity when acting at a public agency's direction | Meadows: Richardson bars qualified immunity for private contractors; Metro employees should not get immunity | Novay/Hodges: They acted under direct instruction and supervision of RHA officials, so immunity applies | Court: Qualified immunity applies because Metro employees acted under direct government supervision/instruction |
| Whether defendants acted under color of state law | Meadows: there were factual disputes about whether Metro acted as private actors | Defendants: acted at RHA's behest as agents performing government functions | Court: District court correctly found they acted under color of state law (not disputed on appeal) |
| Whether the right violated was clearly established | Meadows: argues conduct unlawful and precedent supports denial of immunity | Defendants: no clearly established law putting reasonable official on notice | Court: Even assuming a Fourth Amendment violation, no controlling precedent made the illegality "beyond debate" for supervised private security employees; immunity available |
| Scope of Richardson and Filarsky for private actors performing government duties | Meadows: Richardson controls; private contractors subject to market pressures and not entitled to immunity | Defendants: Filarsky and Richardson permit immunity when private actors perform government functions under government supervision | Court: Richardson remains good law but is narrow; Filarsky supports immunity where private individuals perform government duties at direct instruction; holding limited to closely supervised contractors |
Key Cases Cited
- Richardson v. McKnight, 521 U.S. 399 (1997) (private prison guards not entitled to qualified immunity in context of independent, profit-driven firm with limited government supervision)
- Filarsky v. Delia, 566 U.S. 377 (2012) (private individuals performing government work may be entitled to immunity when functioning as government agents)
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (qualified-immunity two-prong framework requiring violation and clearly established right)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires official policy or custom)
- Reichle v. Howards, 566 U.S. 658 (2012) (clarifies when a right is "clearly established")
- Currie v. Chhabra, 728 F.3d 626 (7th Cir. 2013) (discusses Filarsky's reaffirmation of Richardson and qualified immunity principles)