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Stay Pending Qualified Immunity Interlocutory Appeal Rejected in Arizona Prisoner Death Suit
Maricopa County (Arizona) Sheriff Joseph Arpaio filed a motion to stay litigation pending an interlocutory appeal on the denial of qualified immunity in a lawsuit filed by the parents of Tent City prisoner Phillip Wilson, who was beaten to death while under Arpaio's care and custody. The district court ruled that Arpaio's actions, when construed in the light most favorable to Wilson, constituted deliberate indifference. The stay was therefore denied.
This 42 U.S.C. § 1983 action was brought by Wilson's parents after his fatal beating by fellow prisoners. Arpaio argued that qualified immunity applied and that the court’s statement of the clearly established law in denying him qualified immunity was "way too general."
The U.S. District Court for the District of Arizona held that the law was clearly established and provided adequate warning that a law enforcement officer in Arpaio's position was acting unconstitutionally by being deliberately indifferent. The court held that Wilson had a right to protection from such unconstitutional actions under the Eighth Amendment, and that the three part test in Saucier v. Katz, 533 U.S. 194, 121 S. Ct. 2151, 150 L.Ed.2d 272 (2001) was satisfied, showing deliberate indifference on the part of Arpaio.
The district court further refused to certify Arpaio's interlocutory appeal, finding it was frivolous. See: Wilson v. Maricopa County, 484 F.Supp.2d 1015 (D.Ariz. 2006).
This 42 U.S.C. § 1983 action was brought by Wilson's parents after his fatal beating by fellow prisoners. Arpaio argued that qualified immunity applied and that the court’s statement of the clearly established law in denying him qualified immunity was "way too general."
The U.S. District Court for the District of Arizona held that the law was clearly established and provided adequate warning that a law enforcement officer in Arpaio's position was acting unconstitutionally by being deliberately indifferent. The court held that Wilson had a right to protection from such unconstitutional actions under the Eighth Amendment, and that the three part test in Saucier v. Katz, 533 U.S. 194, 121 S. Ct. 2151, 150 L.Ed.2d 272 (2001) was satisfied, showing deliberate indifference on the part of Arpaio.
The district court further refused to certify Arpaio's interlocutory appeal, finding it was frivolous. See: Wilson v. Maricopa County, 484 F.Supp.2d 1015 (D.Ariz. 2006).
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Related legal case
Wilson v. Maricopa County
| Year | 2006 |
|---|---|
| Cite | 484 F.Supp.2d 1015 (D.Ariz. 2006) |
| Level | District Court |
| Injunction Status | N/A |