Reynolds v. Dormire
2011 U.S. App. LEXIS 3423
| 8th Cir. | 2011Background
- Reynolds, a Missouri inmate, sued under 42 U.S.C. § 1983 alleging Eighth Amendment violations arising from conditions of confinement at JCCC and actions by NCC and JCCC corrections officers, plus the warden.
- Reynolds alleged two NCC COs restrained him throughout a day-long trip to a medical appointment and refused his bathroom requests.
- Reynolds alleged five JCCC COs were deliberately indifferent by parking a van near a sally-port pit and by failing to assist him during exit, causing a five-foot fall and injuries.
- Reynolds claimed Warden Dormire, in his individual capacity, failed to eliminate hazardous sally-port conditions and to train subordinates adequately.
- The district court dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915A; Reynolds appealed pro se and the Eighth Circuit reviewed de novo, with consideration of attached exhibits.
- The court affirmed in part and reversed in part, remanding for further proceedings consistent with its opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the NCC COs violated the Eighth Amendment by restraining Reynolds. | Reynolds alleges deliberate indifference by the two NCC COs. | NCC COs acted to restrain Reynolds for safety; no demonstrated deliberate indifference. | Dismissed; no deliberate indifference shown. |
| Whether King and John Doe I violated the Eighth Amendment for the sally-port fall. | Allegations show substantial risk and recklessness by parking and supervision. | At most negligence; no evidence of deliberate indifference. | Sufficient factual allegations to withstand dismissal; claims proceed. |
| Whether Dormire had personal involvement or causation for the sally-port hazard and training claims. | Warden failed to rectify hazards and inadequately trained staff. | General supervisory duties insufficient for personal liability; no knowledge of risk by warden. | Individual-capacity claim dismissed; official-capacity claim barred by Eleventh Amendment. |
Key Cases Cited
- Ouzts v. Cummins, 825 F.2d 1276 (8th Cir. 1987) (supervisory liability requires personal involvement)
- Martin v. Sargent, 780 F.2d 1334 (8th Cir. 1985) (personal involvement required for § 1983 liability)
- Norman v. Schuetzle, 585 F.3d 1097 (8th Cir. 2009) (deliberate indifference standard; knowledge and disregard)
- Crow v. Montgomery, 403 F.3d 598 (8th Cir. 2005) (reckless disregard as part of deliberate indifference)
- Davis v. Oregon Cnty., Mo., 607 F.3d 543 (8th Cir. 2010) (two-pronged objective/subjective inquiry for risk to inmate)
- Kentucky v. Graham, 473 U.S. 159 (1985) (Eleventh Amendment and official-capacity liability framework)