Manning v. Ryan, No. 20-3490 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's adverse grant of summary judgment based on qualified immunity in a 42 U.S.C. 1983 action brought by a pretrial detainee against prison officials, alleging violation of his constitutional rights when he was denied visitation with his children due to a blanket policy of prohibiting detainees from visitations by minor children. The court determined that its case law up to now has not necessarily made clear that the prison officials violated plaintiff's constitutional rights by enforcing the blanket prohibition on visitation with minor children, and thus qualified immunity was appropriate to protect defendants from liability.
However, the court noted that the time is ripe to clearly establish that such behavior may amount to a constitutional violation in the future. The court joined the Seventh Circuit in holding that prison officials who permanently or arbitrarily deny an inmate visits with family members in disregard of the factors described in Turner v. Safely, 482 U.S. 78 (1987), and Overton v. Bazzetta, 539 U.S. 126 (2003), have acted in violation of the Constitution.
Court Description: [Per Curiam - Before Loken, Kelly, and Erickson, Circuit Judges] Civil case - Civil rights. In this action by a pretrial detainee against jail officials after he was denied visits with his children under a blanket policy denying pretrial detainees such visits, the district court did not err in granting defendants' motion for summary judgment based on qualified immunity as this court's cases have not necessarily made it clear that such a policy violates a detainee's constitutional rights; however, the time is ripe to clearly establish that such behavior by jail officials in the future may amount to a constitutional violation. Held: prison officials who permanently or arbitrarily deny an inmate visits with family members in disregard of the factors set out in Turner v. Safely, 482 u.S. 78 (1987) and Overton v. Bazetta, 539 U.S. 126 (2003), have acted in violation of the Constitution.
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