Williams v. Mannis, No. 17-2017 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment based on qualified immunity and state statutory immunity. Plaintiff had filed suit against defendant and others, alleging claims under 42 U.S.C. 1983 for deliberate conduct that shocks the conscience and a state law claim for outrage. The court held that plaintiff failed to demonstrate sufficient facts to give rise to a triable question as to an alleged violation of a constitutional right. In this case, while law enforcement corruptly conducting an investigation with a view towards presenting knowingly false charges against an innocent person might well represent an instance of conscience-shocking behavior, plaintiff has not presented any evidence beyond surmise that would allow a reasonable finder of fact to conclude that this happened. Therefore, the district court erred in denying qualified immunity to defendant. Likewise, plaintiff's state law claim failed for the same reasons as the federal claim. The district court did not err in denying summary judgment for defendant on the ground of state statutory immunity.
Court Description: Erickson, Author, withe Wollman and Shepherd, Circuit Judges] Civil case - Civil rights. In this appeal of an order denying defendant's motion for summary judgment based on qualified immunity, the district court erred in denying the motion; while law enforcement corruptly conducting an investigation with a view towards presenting knowingly false charges against an innocent person might well represent the type of conscience-shocking behavior needed to establish a Section 1983 claim, plaintiff did not present any evidence beyond surmise that would allow a reasonable fact-finder to conclude that this happened; defendant was also entitled to state law statutory immunity on plaintiff's claims for the tort of outrage as the evidence failed to show he intended to inflict emotional distress on plaintiff or engage in outrageous conduct.
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