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Guards’ Individual Immunity a Matter of Bad Faith Intent
Guards' Individual Immunity a Matter of Bad Faith Intent
Former Kentucky State prisoner William Sloas' voluntary participation in the Rowan County Jail's work program resulted in his leg being broken in an accident. He brought suit against the county and jail officials and, after mixed judgments, the action was dismissed in the Kentucky Supreme Court after finding no "bad faith" by the individual defendants.
While clearing brush and trees from a county road in January 1998, prisoner Carl Lewis cut down a tree. Sloas, attempting to light a cigarette and not paying attention, walked into the falling tree's path. He was treated at no cost to him and was released from jail in April 1998. His suit claimed negligent supervision and training of staff without implementing an adequate safety procedure. Guards Don Hall and Paul Henderson were also sued in their individual capacities, and Sloas claimed vicarious liability for the negligence of Henderson and Lewis.
The court found that the county had sovereign immunity and the guards had absolute immunity in their official capacities and qualified immunity in their individual capacities, and granted the defendants summary judgment on all claims. On appeal, the appellate court affirmed the lower court's ruling except as to Hall and Henderson in their individual capacities, as there were "genuine issues of material fact with regards to whether Sloas' statutory rights were violated in a manner that would tend to show 'bad faith.'"
On appeal, the Kentucky Supreme Court held that under 42 U.S.C. § 1983, only an employee or official acting beyond his scope of authority received no immunity, stating, "The fact that the action taken was within the outer perimeter of an official's line of duty is enough to render the privilege applicable," and "an act is within the official's jurisdiction if it is not manifestly or palpably beyond his authority." The court further found "no bad faith" and reinstated the trial court's dismissal of all claims. See: Rowan County v. Sloas, 201 S.W.3d 469 (Ky. 2006).
Former Kentucky State prisoner William Sloas' voluntary participation in the Rowan County Jail's work program resulted in his leg being broken in an accident. He brought suit against the county and jail officials and, after mixed judgments, the action was dismissed in the Kentucky Supreme Court after finding no "bad faith" by the individual defendants.
While clearing brush and trees from a county road in January 1998, prisoner Carl Lewis cut down a tree. Sloas, attempting to light a cigarette and not paying attention, walked into the falling tree's path. He was treated at no cost to him and was released from jail in April 1998. His suit claimed negligent supervision and training of staff without implementing an adequate safety procedure. Guards Don Hall and Paul Henderson were also sued in their individual capacities, and Sloas claimed vicarious liability for the negligence of Henderson and Lewis.
The court found that the county had sovereign immunity and the guards had absolute immunity in their official capacities and qualified immunity in their individual capacities, and granted the defendants summary judgment on all claims. On appeal, the appellate court affirmed the lower court's ruling except as to Hall and Henderson in their individual capacities, as there were "genuine issues of material fact with regards to whether Sloas' statutory rights were violated in a manner that would tend to show 'bad faith.'"
On appeal, the Kentucky Supreme Court held that under 42 U.S.C. § 1983, only an employee or official acting beyond his scope of authority received no immunity, stating, "The fact that the action taken was within the outer perimeter of an official's line of duty is enough to render the privilege applicable," and "an act is within the official's jurisdiction if it is not manifestly or palpably beyond his authority." The court further found "no bad faith" and reinstated the trial court's dismissal of all claims. See: Rowan County v. Sloas, 201 S.W.3d 469 (Ky. 2006).
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Related legal case
Rowan County v. Sloas
| Year | 2006 |
|---|---|
| Cite | 201 S.W.3d 469 (Ky. 2006) |
| Level | State Supreme Court |
| Injunction Status | N/A |