Michael Leslie Lake v. Michael Skelton
2016 U.S. App. LEXIS 19774
| 11th Cir. | 2016Background
- Michael Lake, a pretrial detainee who claimed a religious vow to abstain from meat, requested a vegetarian diet while held at the Cobb County Adult Detention Center; jail staff initially denied the request and later accommodated it.
- Lake sued Major Michael Skelton (a deputy/operational support commander) in both official and individual capacities under 42 U.S.C. § 1983 and RLUIPA, seeking declaratory relief, damages, fees, and costs for alleged First and Fourteenth Amendment and RLUIPA violations.
- The district court granted summary judgment to Skelton in his individual capacity but denied summary judgment for his official-capacity damages exposure on the ground that Georgia sovereign immunity did not extend to him.
- Skelton appealed interlocutorily the denial of official-capacity immunity; this Court’s review is de novo and limited to the immunity issue.
- The Eleventh Circuit applied the Manders four-factor arm-of-the-state test (function-focused) to the specific function of providing food to inmates and concluded that, under Georgia law, sheriffs/deputies act as arms of the State when denying an inmate’s dietary request.
- The panel reversed the denial of summary judgment and instructed entry of judgment for Skelton on the damages claims, holding Georgia’s sovereign immunity extends to a deputy sheriff performing the feeding function.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Georgia sovereign immunity bars official-capacity damages against a deputy sheriff who denied an inmate's religious dietary request | Lake: feeding/denial is a county responsibility under O.C.G.A. § 42-5-2 so deputy not an arm of the State; immunity does not apply | Skelton: feeding duties derive from state law and statutory jail provisions; deputy acts as an arm of the State for this function | Held: Immunity applies — deputy acted as an arm of the State for the feeding function; summary judgment for Skelton on damages reversed in favor of immunity |
| How to identify the relevant function for Manders analysis | Lake: focus on feeding inmates in county jail (a function tied to county custody) | Skelton: focus likewise on feeding, but contends state law assigns and controls that duty | Held: Court framed the function narrowly as providing food/dietary decisions for inmates and analyzed state law accordingly |
| How state law defines the function — state vs. county actor | Lake: § 42-5-2 assigns duty to the governmental unit having custody (county); Georgia caselaw construes § 42-5-2 as imposing county responsibility | Skelton: statutes (e.g., § 42-4-32, § 42-4-4) impose feeding duties directly on sheriffs and deputies; deputies take their role from sheriff’s state-derived powers | Held: Court concluded state law defines feeding as a state-assigned custodial duty performed by sheriffs/deputies (state hat) — factor favors immunity |
| Where Georgia law vests control and who would pay judgments | Lake: county funds and contracts show county control and financial responsibility; judgments would not burden state treasury | Skelton: state regulates meal standards and disciplines/trains deputies; state control exists even if counties fund much of operations | Held: Court found state law vests regulatory and disciplinary control in the State (factor favors immunity); source-of-funds and judgment-payment factors only slightly favor or do not defeat immunity per Manders |
Key Cases Cited
- Hans v. Louisiana, 134 U.S. 1 (establishes Eleventh Amendment immunity for states from suits by their own citizens)
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (framework for official-capacity liability analysis referenced in arm-of-the-state inquiry)
- Manders v. Lee, 338 F.3d 1304 (11th Cir.) (en banc) (established four-factor test to determine when an official acts as an arm of the State)
- Black v. Wigington, 811 F.3d 1259 (11th Cir. 2016) (procedural authority limiting interlocutory appeal scope re: immunity)
- Miccosukee Tribe of Indians v. Fla. State Athletic Comm’n, 226 F.3d 1226 (11th Cir. 2000) (pre‑Manders arm-of-the-state factor discussion cited for background)
- Abusaid v. Hillsborough Cty. Bd. of Cty. Com’rs, 405 F.3d 1298 (11th Cir. 2005) (analysis of treasury-impact factor and relevance to immunity)
- Pellitteri v. Prine, 776 F.3d 777 (11th Cir. 2015) (state certification and discipline of deputies as evidence of state control)