Edwards, Jr., et al. v. Byrd, et al., No. 13-1560 (8th Cir. 2014)
Annotate this CasePlaintiffs, pretrial detainees at a detention center, filed suit under 42 U.S.C. 1983 against prison guards and the Sheriff, alleging a variety of constitutional violations. The court concluded that the district court correctly denied summary judgment on the basis of qualified immunity where the record supported a claim of excessive force in violation of the Eighth Amendment. The record also supported a claim for failure to protect plaintiffs from harm in violation of the Due Process Clause and the district court correctly denied the guards qualified immunity on this claim. Given the fact that the Sheriff was not at the detention center, he could not have used excessive force against plaintiffs, nor could he have an opportunity to intervene to prevent the guards from employing excessive force. Accordingly, the court reversed the district court's denial of summary judgment based on qualified immunity with respect to the Sheriff. The court affirmed in all other respects.
Court Description: Prisoner case - Civil rights. In an action alleging defendants used excessive force against plaintiffs, pretrial detainees at the Faulkner County, Arkansas jail, the district court did not err in denying the defendants' motions for summary judgment based on qualified immunity because the facts, as found by the district court for the purposes of the summary judgment motion, would support a claim of excessive force in violation of the Eighth Amendment; the facts as found would also support plaintiffs' claim that defendants failed to protect the plaintiffs from harm in violation of the Due Process Clause; however, defendant Boyd, the sheriff, was not present at the jail on the date of the event in question, and he was entitled to qualified immunity on plaintiffs' individual-capacity excessive-force and failure-to-protect claims.
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