Jacoby v. Baldwin County, No. 14-12932 (11th Cir. 2016)Annotate this Case
Plaintiff filed suit against Sheriff Huey Mack and others, alleging claims under 42 U.S.C. 1983, arising from his detention as a pretrial detainee at the Baldwin jail. On appeal, plaintiff argues that Sheriff Mack violated his substantive due process rights by confining him in an unsanitary and overcrowded cell. Defendant also argues that Sheriff Mack violated his procedural due process rights at his August 15, 2012, disciplinary hearing. The court concluded that plaintiff's allegations - that he was temporarily forced to sleep on a mattress on the floor near the toilet - are not enough to clearly establish that his conditions of confinement were unconstitutional. The court also concluded that, although plaintiff was entitled to the due process hearing he received before being punished for his misconduct while in jail, plaintiff failed to overcome Sheriff Mack’s qualified immunity defense on either of his claims. Accordingly, the court affirmed the district court's grant of summary judgment to defendants.