Thurmond v. Andrews, No. 19-1557 (8th Cir. 2020)
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Plaintiffs, six former inmates of the Faulkner County Detention Center, filed suit against the County and two jail employees under 42 U.S.C. 1983, alleging that their conditions of confinement were unconstitutional because of mold in and around the jail's shower.
The Eighth Circuit reversed in part and held that the district court erred in denying the individual jail employees summary judgment based on qualified immunity. The court held that the only thing clearly established in this case is that the definition of the asserted constitutional right embraced by the district court — a right to sanitary prison conditions — was impermissibly broad. The court also held that a finding that such a right was clearly established based on this general definition was therefore in error. Because the right at issue has not been properly defined and there are genuine disputes of material fact at play, it is not possible for the court to determine whether the individual officers committed a constitutional violation in the detention center due to the presence of Cladosporium. Finally, the court held that it lacked jurisdiction to reach the County's appeal where the question of whether the County was liable for failing to train its officers is not inextricably intertwined with the matter of qualified immunity.
Court Description: [Grasz, Author, with Loken, Circuit Judge, and Pitlyk, District Judge] Civil case - Civil rights. In action alleging conditions at the Faulkner County Jail were unconstitutional because of mold in the jail showers, the district court erred in denying the individual jail defendants' motion for summary judgment based on qualified immunity; the definition of the asserted right embraced by the district - the right to sanitary prison conditions - was impermissibly broad; even if framed more specifically as the right to be free from Cladosporium, mold or other allergens in a prison context at the levels alleged here, that right was not clearly established in Eighth Circuit precedent, and the individual jail defendants were entitled to qualified immunity; the question of whether the County was liable failing to train its officers is not inextricably intertwined with the matter of qualified immunity, and the court lacks jurisdiction to hear the County's appeal from the denial of its motion for summary judgment.
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