Cox v. Glanz, No. 14-5022 (10th Cir. 2015)
Annotate this CaseCharles Jernegan committed suicide at the David L. Moss Criminal Justice Center in Tulsa, Oklahoma (“Jail”). His mother, Plaintiff-Appellee Carolyn Cox, brought a 42 U.S.C. 1983 action against Defendant-Appellant Tulsa County Sheriff Stanley Glanz. Sheriff Glanz moved for summary judgment, asserting the defense of qualified immunity. The district court denied the Sheriff’s motion (without mentioning qualified immunity) based on the existence of genuinely disputed material facts. In this interlocutory appeal, Sheriff Glanz argued to the Tenth Circuit that extant caselaw at the time of Jernegan’s suicide did not clearly establish that he could be held liable as a supervisor under the circumstances of this case: Jernegan denied having a suicidal intent during booking and no Jail staff members detected a basis for referring him for additional mental-health screening based on their interactions with him. The Sheriff also argued that none of the policies or procedures he had implemented at the Jail could be characterized as the moving force behind any alleged violation of Jernegan’s constitutional rights. Upon review, the Tenth Circuit concluded that under the facts of this case, the district court erred in denying the Sheriff's motion for summary judgment on qualified immunity grounds on Cox's individual-capacity claim. As for Cox's official-capacity claim, the Court concluded that the district court’s denial of the motion for summary judgment was indisputably not a final decision amenable to interlocutory review: "Our assumption of jurisdiction over the court’s resolution of the official-capacity claim would therefore only be appropriate if we invoked our discretionary power to exercise pendent jurisdiction over this claim. Sheriff Glanz, however, has not relied upon this generally disfavored doctrine; furthermore, we discern no legally cognizable basis for exercising pendent appellate jurisdiction under the circumstances of this case." The Sheriff's appeal of the denial of his motion for summary judgment on Cox's official-capacity claim was dismissed for lack of jurisdiction.
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