Estate of Ronald E. Johnson v. Douglas Weber
2015 U.S. App. LEXIS 7327
| 8th Cir. | 2015Background
- Ronald Johnson, a prison guard, was murdered by inmates Berget and Robert at the South Dakota State Penitentiary in 2011.
- Plaintiff Estate and Lynette Johnson brought §1983 and state-law claims for violations of Johnson’s constitutional and state rights.
- District court granted summary judgment on constitutional claims based on qualified immunity; state-law claims remained.
- Johnson alleged defendants’ housing, transfers, and freedom of movement policies permitted dangerous inmates to threaten or harm staff.
- Defendants removed the case to federal court and the district court analyzed Hart factors under the substantive due-process framework.
- The court concluded no clearly established constitutional violation or deliberate indifference, affirming dismissal of the §1983 claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state-created-danger claim survives summary judgment | Johnson argues Hart factors show conscience-shocking conduct | Defendants contend no deliberate indifference and no shock to conscience | No: conduct did not shock the conscience; no deliberate indifference. |
| Whether housing and supervision decisions were conscience-shocking | Johnson asserts too much freedom and inadequate supervision. | Warden discretion allowed under policy; decisions not shocking | No: transfers and housing decisions did not shock conscience given discretion and lack of specific threats. |
| Whether qualified immunity bars the §1983 claims | Johnson seeks to override immunity by alleging constitutional violation | Defendants argue no clearly established violation | Affirmed: no §1983 violation or clearly established right proven. |
Key Cases Cited
- Hart v. City of Little Rock, 432 F.3d 801 (8th Cir. 2005) (two Hart factors for state-created-danger; deliberate indifference standard)
- Saucier v. Katz, 533 U.S. 194 (Supreme Court 2001) (two-step qualified-immunity analysis)
- Moore ex rel. Moore v. Briggs, 381 F.3d 771 (8th Cir. 2004) (deliberate indifference standard analogous to Eighth Amendment standard)
- Farmer v. Brennan, 511 U.S. 825 (Supreme Court 1994) (intent to harm and risk awareness standards in deprivation of life-safety)