Reeves v. King, No. 13-3416 (8th Cir. 2014)
Annotate this CaseReeves, an inmate housed in the isolation unit at Ouachita River Unit in Malvern, provided information to correctional officers about a prison nurse who was bringing contraband into the facility. While Lieutenant King and another officer made security rounds in the unit, Reeves attempted to initiate a conversation with them. King responded by commenting, “Go ahead and snitch to the major like you did to him on the nurse and he’ll get back with you later.” King made this comment in the presence of several inmates, and Reeves suffered emotional distress and fear of retaliation. The next day, Arkansas Department of Corrections transferred Reeves, who then filed suit under 42 U.S.C. 1983, alleging that King violated his Eighth Amendment rights by calling him a snitch. King sought summary judgment. The magistrate determined King was not entitled to qualified immunity because Eighth Circuit precedent provides a detention officer violates his duty to protect an inmate by labeling that inmate as a snitch. The district court adopted the recommendations and denied the motion for summary judgment. The Eighth Circuit affirmed. A reasonable correctional officer in King’s position would have known that labeling Reeves a snitch would violate his constitutional right to protection.
Court Description: Civil case - Civil rights. Defendant's action in revealing to other inmates that plaintiff had "snitched" on a prison employee who was bringing illegal drugs into the prison subjected plaintiff to a substantial risk of serious harm at the hands of his fellow inmates; existing case law at the time sufficiently gave defendant fair warning that his alleged actions violated plaintiff's constitutional rights and he was not, therefore, entitled to summary judgment based on qualified immunity on plaintiff's Eighth Amendment claims.
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