Payne v. Britten, et al., No. 12-3872 (8th Cir. 2014)
Annotate this CasePlaintiff, a prison inmate, filed suit asserting various claims, including 42 U.S.C. 1983 claims alleging violations of the First and Fourteenth Amendments, that prison officials wrongfully censored and confiscated his mail. The court concluded that when an official properly and timely files a motion for dismissal or for summary judgment asserting qualified immunity, the official was entitled to a ruling on the issue of qualified immunity. As such, the district court must issue a reviewable ruling before requiring the officials to progress further in litigation at the district court. Therefore, the court reversed the district court's order converting the officials' motion to dismiss into a motion for summary judgment; vacated the district court's partial denial of the officials' motion for summary judgment; and remanded with instructions for the district court to decide, consistent with this opinion, whether the officials were entitled to qualified immunity on the pleadings under Rule 12(b)(6).
Court Description: Prisoner case - Prisoner civil rights. When an official properly and timely files a motion for dismissal or summary judgment asserting qualified immunity, the official is entitled to a ruling on the issue of qualified immunity; as such, the district court must issue a reviewable ruling - either or granting or denying qualified immunity - before requiring the officials to progress further in the litigation; here, where the district court declined to rule on the issue, the district court's order converting the officials' motion to dismiss into a motion for summary judgment is reversed, and its partial denial of the officials' motion for summary judgment is vacated; the matter is remanded with instructions for the district court to decide, consistent with this opinion, whether the officials are entitled to qualified immunity on the pleadings under Rule 12(b)(6). Chief Judge Riley, concurring in part and dissenting in part.
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