Walton v. Dawson, et al., No. 12-4000 (8th Cir. 2014)Annotate this Case
Plaintiff, a victim of sexual assault while in pretrial detention in jail, filed suit under 42 U.S.C. 1983 and pendent state law, alleging claims against those he considered responsible for the assault. At issue in this interlocutory appeal are plaintiff's Fourteenth Amendment failure to train claims against the sheriff and the jail administrator. The court denied plaintiff's motion to dismiss the appeal for lack of jurisdiction because the court had jurisdiction over the case under the collateral order doctrine. On the merits, the court concluded that plaintiff's failure to train and supervise claims must be judged by Farmer v. Brennan's subjective deliberate indifference standard where plaintiff must prove that the prison officials personally knew of the constitutional risk posed by their inadequate training or supervision and proximately caused him injury by failing to take sufficient remedial action. The court concluded that the district court's findings of fact adequately supported the district court's legal conclusion that the administrator was not presently entitled to qualified immunity on plaintiff's claim that the administrator failed to train a jailer regarding the jail's policy to lock the cell doors overnight. The court found nothing but speculation, conjecture, or fantasy to rebut the sheriff's testimony that he did not know of the substantial risk posed by the administrator's failure to train the jailer. Accordingly, the court affirmed the denial of qualified immunity to the administrator, reversed the denial of qualified immunity to the sheriff, and remanded for further proceedings.