Beard v. Falkenrath, No. 22-2893 (8th Cir. 2024)
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In the case, Sease Beard, a transgender inmate, alleges mistreatment and retaliation by prison officials. Beard, who identifies as a transgender woman, has been provided hormone-replacement therapy by the Missouri Department of Corrections since 2019. The issue in the case centers on whether the prison officials are shielded by qualified immunity.
Beard was involved in multiple incidents with guards. In one particular incident, when a guard expressed disapproval of Beard's attire, Beard refused to change. Subsequently, several guards physically restrained Beard, used pepper spray, removed Beard's clothes, and carried Beard through the prison's hallways in view of other inmates. Following this incident, Beard filed a lawsuit against nearly everyone involved, claiming violations of state law and the First, Fourth, Eighth, and Fourteenth Amendments to the United States Constitution.
The lower court, the United States District Court for the Western District of Missouri, denied the officials' motion to dismiss the case, asserting their claim to qualified immunity.
The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision in part and reversed in part. The court found that certain prison officials were not entitled to qualified immunity for some of Beard's claims, including a Fourth Amendment claim regarding a strip search and First Amendment retaliation claims related to denial of a promotion, restriction of shower access, and confiscation of personal property. However, the court found that other officials were entitled to qualified immunity for claims related to the denial of mental health treatment and the supervisors' inaction. The case was sent back to the district court for further proceedings.
Court Description: [Stras, Author, with Shepherd and Kelly, Circuit Judges] Civil case - Civil rights. Plaintiff, an inmate at an all-male prison who has gender dysphoria and identifies as a transgender woman, sued prison officials asserting various federal civil rights claims. The claims arose out of an incident during which plaintiff was allegedly forcibly stripped of all clothing except underwear by male guards, pepper sprayed, placed in restraints, exposed to other inmates while largely unclothed, and then placed on suicide watch. Plaintiff also asserted violations of a right to wear gender-identity-conforming clothing and to have others use preferred pronouns and claimed that various defendants retaliated against plaintiff after this lawsuit was filed. The district court denied defendants' motion to dismiss plaintiff's operative complaint based on qualified immunity, and defendants appeal. Held: The district court did not err in denying defendants qualified immunity on plaintiff's Fourth Amendment unlawful search claim as the search plausibly crossed the line into unreasonableness; defendants are entitled to qualified immunity on plaintiff's equal protection and First Amendment expressive-conduct claims, as it was not clearly established at the time of the incident that they would violate plaintiff's constitutional rights by engaging in the gender-identity discrimination alleged; plaintiff's complaint was insufficient to state deliberate-indifference or First Amendment retaliation claims against two defendants; and the district court did not err in denying qualified immunity on the remaining retaliation claims, as the complaint allegations were sufficient to support an inference of retaliatory motive and but-for causation between the filing of this lawsuit and the subsequent denial of plaintiff's request to be promoted out of administrative segregation, new restrictions on plaintiff's access to showers, and the confiscation of plaintiff's personal property, including legal materials. The denial of the motion to dismiss is affirmed as to plaintiff's Fourth Amendment claims against the guards involved in the search, affirmed in part as to the retaliation claims, and otherwise reversed. Judge Kelly, concurring in part and dissenting in part.
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