Lee Andrew Jackson v. Glynn County Georgia
683 F. App'x 867
| 11th Cir. | 2017Background
- Jackson, a paraplegic, was arrested for DUI and kept in his wheelchair overnight at Glynn County Detention Center pending intake, which required a shower.
- Officers Travis Smith and Shawn Davies assisted with moving Jackson for a shower; Jackson complained of back pain when lifted, and officers returned him to his wheelchair.
- Jail staff notified a supervisor; Jackson’s family brought medication; a jail doctor examined Jackson ~1:55 p.m. and authorized his medications (including hydrocodone) and placement in a cell.
- Jackson later sought further treatment from his GP and filed a § 1983 suit, ADA claim, and Georgia law claims against Glynn County, Sheriff Wayne Bennett (official and individual), and Officer Davies (individual and official).
- The district court struck Jackson’s affidavit as a sham, granted summary judgment to County, Bennett, and Davies on Eleventh Amendment, qualified immunity, lack of supervisory causation, and Georgia-law immunity grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of affidavit | Jackson: affidavit factualizes officers’ joint lifting and attributes injury to both, creating factual dispute | Defendants: affidavit contradicts prior deposition and is a sham intended to create dispute | Court: affidavit properly struck as inconsistent with deposition; no abuse of discretion |
| County liability under §1983/ADA | Jackson: County liable for ADA violations and §1983 due to inadequate shower facilities and policies | County: Sheriff operates jail under state authority; County lacks control over sheriff’s jail policies/resources | Court: Glynn County not liable; sheriff acts under state authority, so County lacks control for ADA/§1983 liability |
| Official-capacity claims against Sheriff (Eleventh Amendment) | Jackson: Bennett is a county officer and subject to suit | Bennett: acts as an arm of the State when administering jail; Eleventh Amendment bars suit | Court: Official-capacity claims barred by Eleventh Amendment; Bennett acted as arm of state |
| Individual liability / qualified immunity (Sheriff & Officer) | Jackson: Bennett failed to provide medical care, train, or adopt policies; Davies used excessive force / caused injury | Defendants: No evidence Bennett knew of injury or widespread abuse; jail doctor treated Jackson; Davies did not touch Jackson when injury occurred and aided him | Court: Qualified immunity for Bennett and Davies; Jackson failed to show deliberate indifference, supervisory causation, or constitutional violation |
Key Cases Cited
- Furcron v. Mail Centers Plus, LLC, 843 F.3d 1295 (11th Cir. 2016) (standard for striking sham affidavits)
- Singletary v. Vargas, 804 F.3d 1174 (11th Cir. 2015) (summary judgment de novo standard)
- Access Now, Inc. v. Sw. Airlines Co., 385 F.3d 1324 (11th Cir. 2004) (issues not raised below generally not considered on appeal)
- Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003) (sheriff acts as state actor in jail administration)
- Brown v. Dorsey, 625 S.E.2d 16 (Ga. Ct. App. 2005) (Georgia law: sheriff independent from county control)
- Teasley v. Freeman, 699 S.E.2d 39 (Ga. Ct. App. 2010) (sheriff may be county employer for workers’ comp but not controlled by county for jail duties)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for serious medical needs)
- Braddy v. Fla. Dep’t of Labor & Employment Sec., 133 F.3d 797 (11th Cir. 1998) (supervisory liability requires causal connection)
- Gilmore v. Hodges, 738 F.3d 266 (11th Cir. 2013) (qualified immunity framework)