Hayden v. NEVADA COUNTY, AR
2012 U.S. App. LEXIS 472
| 8th Cir. | 2012Background
- Hayden, the plaintiff, sues Nevada County and Sheriff Mormon under 42 U.S.C. § 1983 for due process violations arising from a December 1989 guilty plea to terroristic threatening.
- Hayden allegedly was coerced to plead guilty in pretrial custody, with Mormon purportedly promising two years of probation and release by Christmas.
- Hayden contends he lacked understanding of the charge and that Mormon knew he was incompetent, but the district court granted summary judgment for Mormon on qualified immunity.
- Arkansas law required counsel and a knowing, voluntary waiver for a felony guilty plea; the record does not show the round of proceedings, but ASH had previously opined him competent.
- Hayden later was convicted on related offenses, serving time due to probation from the 1989 plea; in 2006 a coram nobis petition led to a finding Hayden was then incompetent to stand trial.
- The district court held Mormon not liable because the trial judge, not the Sheriff, determines competence; no proximate causation was shown for the plea coerced by Mormon.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mormon violated Hayden's due process by coercing a guilty plea | Hayden argues coercive advice violated due process. | Mormon did not render the plea involuntary; he relied on a competent-stand-trial assessment. | No due process violation found; coercion did not render plea involuntary. |
| Whether there is causation support for § 1983 liability against Mormon | Hayden claims Mormon's statements proximate cause of the violation. | No proximate causation; delay or missteps were not shown to be caused by Mormon. | Plaintiff failed to show proximate cause; summary judgment proper on causation. |
| Whether Nevada County and Mormon in official capacity can be liable for training failures | County failed to train officers who give unqualified legal advice to detainees. | Conjectural training deficiency; no fact showing deliberate indifference. | Summary judgment affirmed; insufficient evidence of training failure fact. |
Key Cases Cited
- Brady v. United States, 397 U.S. 742 (1970) (plea involuntariness standard for coercion)
- Godinez v. Moran, 509 U.S. 389 (1993) (competency to stand trial standard and waiver validity)
- Hunter v. Bowersox, 172 F.3d 1016 (8th Cir.1999) (competency and waiver determinations in pretrial context)
- Walden v. Carmack, 156 F.3d 861 (8th Cir.1998) (sheriff not liable for recommending excessive bail)
- Latimore v. Widseth, 7 F.3d 709 (8th Cir.1993) (proximate-cause requirement in § 1983)
- Morton v. Becker, 793 F.2d 185 (8th Cir.1986) (causation element in § 1983 action)
- Martinez v. California, 444 U.S. 277 (1980) (reaffirmed requirement of causation and constitutional rights)
- Campbell v. Lockhart, 789 F.2d 644 (8th Cir.1986) (duty to ensure competency and waivers in proceedings)