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Eleventh Circuit Condemns One-Sentence Qualified Immunity Denial Order

The Eleventh Circuit Court of Appeals has reversed an Alabama federal district court?s order denying jail officials? motions to dismiss on qualified immunity ground, admonishing the district court for only entering ?one sentence orders denying? the motions.

Kevin Danley sued under 42 U.S.C. § 1983, alleging ?he was subjected to excessive force and then denied medical treatment when, as a pretrial detainee, detention officers sprayed him with pepper spray? while he was a pretrial detainee in the Lauderdale County Detention Center. The district court?s orders ?perfunctorily stated? it had considered the defendants? motions to dismiss and was ?of the opinion defendants? motions are to due be denied.?

The Eleventh Circuit said it has admonished, many times, district courts that fail to contain sufficient explanations of their rulings to allow meaningful appellate review. While the Eleventh Circuit could review the record and applicable case law to render a reasoned decision on qualified immunity, ?this is the responsibility of the district court in the first instance.?

The district court?s order was reversed with instructions to enter a reasoned order. See: Danley v. Allen, 480 F.3d 1090 (11th Cir. 2007).
On Remand the district court again denied the defendant jail officials motion for summary judgment, this time in a 15 page opinion. See: Danley v. Allen, 485 F. Supp. 2d 1260 (ND AL 2007)

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Danley v. Allen

Danley v. Allen