McGuire v. Cooper, No. 18-2809 (8th Cir. 2020)
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After plaintiff was sexually assaulted by a deputy acting within the scope of his employment with the sheriff's office, she filed claims of unreasonable search and seizure, equal protection, due process, supervisory liability, and municipal liability under the Civil Rights Act, 42 U.S.C. 1983.
The Eighth Circuit reversed the district court's denial of qualified immunity and summary judgment in favor of the sheriff. The court held that the sheriff was entitled to qualified immunity, because prior instances of sexual misconduct were not similar in kind or sufficiently egregious in nature to demonstrate a pattern of sexual assault against members of the public by deputies. Therefore, a reasonable officer in the sheriff's position would not have known that he needed to more closely supervise his deputies, including defendant, or they might sexually assault a member of the public. Furthermore, a reasonable supervisor in the sheriff's position would not know that a failure to specifically train defendant not to sexually assault a woman would cause defendant to engage in that behavior.
Court Description: [Erickson, Author, with Gruender and Kelly, Circuit Judges] Civil case - Civil rights. In this case, plaintiff alleged Cooper, a Douglas County deputy sheriff, sexually assaulted her and violated her civil rights; the district court denied the Sheriff's motion for summary judgment, and the Sheriff appealed, contending he was entitled to qualified immunity; the district court's order is reversed and the matter is remanded with directions to enter judgment for the Sheriff on the basis of qualified immunity; held, the prior instances of sexual misconduct by deputies were not similar in kind or sufficiently egregious in nature to demonstrate a pattern of sexual assault against members of the public by the deputies; as such, it was not sufficient to put the Sheriff on notice that a deputy might, as Cooper allegedly did, use his position to separate a woman from her boyfriend at a park and coerce her to engage in sexual contact with him; a reasonable officer in the Sheriff's position would not have known that he needed to more closely supervise his deputies or they might sexually assault a member of the public; nor would a reasonable supervisor in the Sheriff's position know that a failure to specifically train Cooper not to sexually assault a woman would cause him to engage in the behavior.
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