Paige Ray-Cluney v. Charles Palmer
906 F.3d 540
| 7th Cir. | 2018Background
- Iowa closed its in-state girls' training school and contracted (through Charles Palmer, Director of Iowa DHS) to place delinquent juveniles at Wisconsin's Copper Lake facility; Iowa paid a per-diem to Wisconsin.
- Plaintiffs Laura Reed and Paige Ray-Cluney (both 16 at placement) allege prolonged, repeated solitary confinement in small concrete cells with minimal amenities, limited out-of-cell time, poor conditions, and repeated use of force (including restraints, head-ramming, mace, and other abuse); both attempted suicide.
- Plaintiffs sued under 42 U.S.C. § 1983 (Fourth, Eighth, and Fourteenth Amendment theories), plus state tort and state-constitutional claims, naming mostly Wisconsin officials and Palmer as the lone Iowa defendant.
- Palmer moved to dismiss on many grounds, including qualified immunity; the district court granted dismissal on qualified-immunity grounds, finding no clearly established law governing Palmer’s role, and dismissed state-law claims for failure to exhaust.
- The Seventh Circuit reviewed de novo and reversed the dismissal as to Palmer, holding that plaintiffs’ well-pleaded allegations sufficed at the Rule 12(b)(6) stage to overcome a qualified-immunity dismissal and to permit discovery on custody, knowledge, and reasonableness questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified immunity at Rule 12(b)(6) | Palmer monitored, retained custody, received reports about Copper Lake, knew/should have known of abusive isolation, and was deliberately indifferent | No controlling precedent clearly establishes constitutional duties for an official in Palmer’s contractual/monitoring role; immunity barred the claims | Reversed: pleadings plausibly allege facts that preclude dismissal on qualified-immunity grounds; factual development required |
| Constitutional standard for juvenile confinement claims | Excessive, prolonged isolation and force violated plaintiffs' constitutional rights (Eighth and/or Fourteenth) | Unclear which Amendment applies and whether confinement was punitive or justified by legitimate objectives | Court: both Eighth- and Fourteenth-Amendment frameworks are relevant; plaintiffs alleged facts that could show a constitutional violation, but merits require further factual inquiry |
| State custody / "special relationship" duty | Iowa retained custody over the girls and thus had a duty to protect them from known dangers even when housed out-of-state | Palmer was remote/contracting party, not the hands-on operator; that separation defeats a duty to supervise | Court: special-relationship precedent can apply where the State retains custody and places children with custodians it knows/suspects to be dangerous; allegations plausibly invoke that duty |
| Pleading standard v. factual development | Complaint contains sufficient factual allegations to present a coherent, plausible claim and infer Palmer's knowledge/responsibility | Qualified immunity can be decided early and dismissal proper because plaintiffs failed to plead specifics about reports/monitoring | Court: at the 12(b)(6) stage plaintiffs need only plausible factual allegations; dismissal premature — further factual development is appropriate |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (establishing the two-step qualified immunity framework and discretion to address prongs in either order)
- Harlow v. Fitzgerald, 457 U.S. 800 (formulation of qualified immunity standard)
- Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate-indifference standard)
- Bell v. Wolfish, 441 U.S. 520 (Fourteenth Amendment analysis for whether conditions of confinement constitute punishment)
- DeShaney v. Winnebago County Dep’t of Soc. Servs., 489 U.S. 189 (no affirmative duty absent custody unless a special relationship exists)
- Youngberg v. Romeo, 457 U.S. 307 (standard for evaluating state-imposed restraints on civilly committed persons; legitimacy/relationship balancing)
- Ingraham v. Wright, 430 U.S. 651 (distinguishing juvenile confinement standards and noting uncertainty whether Eighth or Fourteenth Amendment applies)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clarifying the requirement that rights be clearly established for qualified immunity)