S.M. v. Krigbaum, No. 14-3704 (8th Cir. 2015)
Annotate this CasePlaintiffs, five female Drug Court participants, filed suit under 42 U.S.C. 1983, seeking damages for injuries resulting from sexual abuse by Scott Edwards, a Lieutenant in the Lincoln County Sheriff’s Department, while he acted as “tracker” for the Drug Court. The district court granted Defendant Graham-Thompson qualified immunity and denied Defendant Krigbaum, the County Sheriff, qualified immunity. Krigbaum appealed. The court reversed the denial of qualified immunity on Krigbaum, concluding that he did not have notice of a pattern of conduct by Edwards that violated a clearly established constitutional right; plaintiffs presented no evidence that Krigbaum had knowledge of sexual misconduct by Edwards that would create an inference Krigbaum turned a blind eye to or consciously disregarded a substantial risk of the constitutional harm Edwards was causing - conscience-shocking violations of plaintiffs’ substantive due process rights by a member of the Sheriff’s Department performing duties for the Drug Court; and the policy in question was designed to protect persons and did not “give rise to unconstitutional conditions.”
Court Description: Loken, Author, with Beam and Shepherd, Circuit Judges] Civil Case - civil rights - qualified immunity. The denial of qualified immunity to sheriff on claim of failure to train or supervise is reversed, as there was no evidence sheriff received notice of a pattern of unconstitutional acts and conduct he observed fell far short of a pattern of conduct that violated substantive due process; district court also erred in ignoring admission that sheriff lacked actual knowledge of facts necessary to show he was deliberately indifferent. In addition, sheriff could not be deliberately indifferent in failing to satisfy a duty he did not know he had. Sheriff had no information that would have raised an inference that officer was violating his training and duties as a police officer. Failure to enforce a call-in policy did not give rise to an unconstitutional condition.
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