Roger Johnson v. Hinds County Board of Suprs, et a
694 F. App'x 945
5th Cir.2017Background
- Roger Johnson, a pretrial detainee at Hinds County Detention Center (Raymond, MS), sued under 42 U.S.C. § 1983 alleging officials failed to protect him from inmate violence.
- Defendants moved for summary judgment on qualified immunity grounds; the district court denied that motion.
- District court found disputed facts about supervisory knowledge/actions (grievances, placement in protective custody) and about Officer Sanders’ conduct (release of inmate, awareness of location, violations of procedure, response during the assault).
- Defendants appealed the denial of qualified immunity interlocutorily; they also sought review of the denial of a statute-of-limitations dismissal.
- The defendants moved to strike portions of Johnson’s brief challenging the denial of his motion for partial summary judgment, arguing no cross-appeal was filed by Johnson.
- The Fifth Circuit evaluated whether it had jurisdiction to review the denial of qualified immunity and whether to exercise pendent appellate jurisdiction over the limitations ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of summary judgment on qualified immunity for supervisory defendants is appealable | Johnson argues disputed facts preclude immunity; summary judgment denial proper | Supervisors contend record does not create genuine disputed facts and they are entitled to immunity as a matter of law | Appeal dismissed for lack of jurisdiction as material factual disputes exist about supervisors (no review) |
| Whether denial of summary judgment on qualified immunity for Officer Sanders is appealable | Johnson points to factual conflicts about Sanders’ actions that preclude immunity | Sanders contends the evidence does not create a genuine factual dispute and he is entitled to immunity | Appeal dismissed for lack of jurisdiction as material factual disputes exist about Sanders (no review) |
| Whether court should exercise pendent appellate jurisdiction to review denial of statute-of-limitations defense | Johnson opposes reaching limitations issue on appeal | Defendants ask appellate court to address statute-of-limitations denial along with immunity denial | Court declines pendent jurisdiction; limitations ruling not "inextricably intertwined" with immunity denial |
| Whether portions of Johnson’s brief about his denied motion for partial summary judgment should be struck (no cross-appeal) | Johnson included argument without filing cross-appeal | Defendants moved to strike those portions as unauthorized | Motion to strike granted |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (establishes deliberate indifference standard for failure-to-protect claims)
- Johnson v. Jones, 515 U.S. 304 (1995) (limits interlocutory appeals on qualified immunity when genuine factual disputes exist)
- Naylor v. State of La., Dep’t of Corr., 123 F.3d 855 (5th Cir. 1997) (jurisdictional limits on appeals from qualified immunity denials)
- Manis v. Lawson, 585 F.3d 839 (5th Cir. 2009) (appellate review may determine whether disputed facts are material)
- Hare v. City of Corinth, Miss., 74 F.3d 633 (5th Cir. 1996) (applies deliberate-indifference standard to pretrial detainees)
- Domino v. Texas Dep’t of Criminal Justice, 239 F.3d 752 (5th Cir. 2001) (describes high threshold for deliberate indifference)
- Aldy on Behalf of Aldy v. Valmet Paper Machinery, 74 F.3d 72 (5th Cir. 1996) (discusses pendent appellate jurisdiction)
- Thornton v. Gen. Motors Corp., 136 F.3d 450 (5th Cir. 1998) (limits exercise of pendent appellate jurisdiction)