Uinta County v. Pennington
286 P.3d 138
Wyo.2012Background
- Pennington, an inmate, was sexually assaulted by Hoover, a detention officer, at the Uinta County Detention Center.
- Pennington brought claims under the Wyoming Governmental Claims Act against Sheriff Napoli, the County, and the Board for damages due to the assault.
- Trial court denied summary judgment to the Sheriff on negligent supervision and training and denied qualified immunity; it also denied the County/Board's statutorily imposed liability.
- The Sheriff and County appealed, arguing entitlement to summary judgment on negligent supervision and training and on qualified immunity.
- The appellate court reversed, holding Sheriff Napoli was entitled to qualified immunity and that there was no vicarious liability against the County/Board if the officer is immune.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sheriff Napoli is entitled to qualified immunity. | Pennington argues Napoli was not acting in good faith or reasonably. | Napoli argues he acted within discretionary duties and reasonably, with good faith. | Yes, Napoli is entitled to qualified immunity. |
Key Cases Cited
- Darrar v. Bourke, 910 P.2d 572 (Wyo.1996) (test for qualified immunity and good faith; discretionary duties)
- Blake v. Rupe, 651 P.2d 1096 (Wyo.1982) (immunity policy origins; public official immunity rationale)
- Kimbley v. City of Green River, 663 P.2d 871 (Wyo.1983) (defense preserved despite Governmental Claims Act waiver)
- Layland v. Stevens, 171 P.3d 1070 (Wyo.2007) (question of law vs. fact in immunity analysis)
- Rice v. Collins Communication, Inc., 283 P.3d 1009 (Wyo.2010) (good faith review not always require detailed testimonial parsing)