Sandknop v. O'Connell, No. 18-2807 (8th Cir. 2019)
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Plaintiff filed a pro se complaint alleging a 42 U.S.C. 1983 claim against MDOC, the warden of OCC, and a former probation and parole officer at the OCC, alleging that he was unlawfully deprived of his liberty as a result of statements made by the former probation and parole officer to a local state court. The district court granted the warden and the officer absolute and qualified immunity, and plaintiff appealed the assistance of pro bono counsel.
The Eighth Circuit affirmed and held that plaintiff's complaint failed to contain sufficient allegations to overcome qualified immunity with regard to any statement the probation officer made to the state court before the court issued the order requiring plaintiff to be detained further. Furthermore, the complaint did not provide any other reason that either the warden or the probation officer violated a clearly established constitutional right.
Court Description: Erickson, Author, with Colloton and Gruender, Circuit Judges] Prisoner Case - Civil Rights. Civil rights claim that Sandknop was deprived of his liberty as a result of misstatement made by former probation officer to state court was dismissed on absolute and qualafied immunity grounds. District court did not err in dismissing based on qualified immunity, as qualified immunity established on the fact of the complaint. Official does not violate a defendant's constitutional rights by making an erroneous statement of law to a state court.
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