Michael Handt v. Steve Koffron
2012 U.S. App. LEXIS 12044
| 8th Cir. | 2012Background
- Handt was sentenced on June 2, 2008 to placement in a 321J program with Pre-Placement Supervision; failure to comply could lead to custody and possible modification of sentence.
- Despite the order, Sheriff Lynch and deputies arrested Handt the next day and transported him to IMCC without a certified copy of the sentencing order.
- At IMCC, intake officers strip-searched Handt during admission, before a certified copy of the execution was received.
- Two certified copies of the sentencing order were later transmitted to IMCC, but Handt argued the order did not authorize imprisonment at IMCC.
- Handt notified his assigned counselor Carson via kites that his detention violated the sentencing order; Carson allegedly ignored these notices.
- A state judge later ordered Handt returned home and the original sentencing order followed; Handt was released pending bed availability in the program.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly analyzed qualified immunity for all claims | Handt asserts insufficient, incomplete immunity analysis. | Koffron/Jacobsen/Takes and Carson contend proper analysis was performed or remand appropriate. | Remand for full qualified-immunity analysis. |
| Whether Handt's Fourth Amendment rights were violated by the intake and detention at IMCC | Detention without proper basis violated Fourth Amendment rights. | Actions followed court order or reasonable procedures; no clearly established violation. | Remand; district court must assess immunity with complete record. |
| Whether Handt's procedural due process rights were violated by the intake and detention | Due process required proper notification and review of custody per order. | Procedural issues were disputed factual questions; immunity analysis needed. | Remand; require full qualified-immunity evaluation. |
Key Cases Cited
- Johnson v. Jones, 515 U.S. 304 (1995) (collateral-order review of immunity questions; purely legal issues)
- Langford v. Norris, 614 F.3d 445 (8th Cir. 2010) (purely legal question for interlocutory appeal under collateral order doctrine)
- White v. McKinley, 519 F.3d 806 (8th Cir. 2008) (identifies scope of qualified-immunity review on appeal)
- O’Neil v. City of Iowa City, 496 F.3d 915 (8th Cir. 2007) (standard for evaluating evidence when applying qualified immunity)
- Jones v. McNeese, 675 F.3d 1158 (8th Cir. 2012) (district court must conduct complete immunity analysis; not cursory)
- Pearson v. Callahan, 555 U.S. 223 (2009) (two-prong approach to qualified immunity; prong may be addressed in any order)
- Mitchell v. Forsyth, 472 U.S. 511 (1985) (immunity is an immunity from suit; must be decided before trial)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (policy-based protection for government officials when performing discretionary functions)
- Kentucky v. Graham, 473 U.S. 159 (1985) (standard for evaluating individual-capacity §1983 claims)