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Bureaucracy Errors that Result in Overdetention Not Deliberate Indifference

The Eleventh Circuit Court of Appeals has held that the overdetention of two prisoners was not due to deliberate indifference on the part of officials at Alabama’s Mobile County Jail. The Court’s ruling affirmed the grant of summary judgment to the defendants.

The 42 U.S.C. § 1983 action alleged Fourth Amendment violations for the overdetentions of plaintiffs Bentley West and Jerry Rainey. West was incarcerated on November 2, 2002, for a marijuana possession charge. On December 4, a court order lowered his bond, allowing him to execute a signature bond on his behalf. Despite that, he was not released until December 27.

Rainey was jailed on October 31, 2002, on robbery charges. A grand jury no-billed him on March 27, 2003, and a court order to release him was sent to the jail that day. Nonetheless, he was not released until May 24. The Alabama federal district court found the defendants were entitled to qualified immunity.

The defendants fell into two classes: non-supervisory and supervisory. The Eleventh Circuit stated that human error does not equal deliberate indifference. The Court found that the plaintiffs failed to demonstrate anything more than their overdetention resulted from negligence or human error.

A common problem contributed to the overdetentions. The record showed the Jail receives anywhere from 5,000 to 12,000 different court orders per month, sometimes with a volume of up to 2,000 or 3,000 documents per week. In 2000, the Jail’s records department staff was downsized from six people to two or three. It was not until April 2003 that the records department came back to full staff of six people.

According to the record, West’s release order was entered into the computer, but his release papers simply “fell between the gaps” because of the volume of work in the records. There is no evidence that any defendant was deliberately indifferent or that they deliberately disregarded West’s rights by failing to ensure that the proper documents were delivered to secure his release. In fact, one defendant looked into the matter for West, resulting in his release the second time. The Court found Rainey’s case even weaker because he could not identify which defendant handled his release documents.

As to the Supervisory defendant, the evidence did not constitute widespread abuse sufficient to notify them that deprivations were obvious, flagrant, rampant, and of continued duration, rather than isolated occurrences.

In fact, the supervisors were aware of the staffing problems. They responded to this by installing the computer system and pulling staff from other departments to assist with the paperwork flow. Because staff errors were occasional, there was no claim that there was a failure to train. Although the training could result in mistakes, no evidence was presented that there was a known need for a different kind of training. Finally, there was no failure to supervise shown by the evidence. There was no showing that overdetentions were regular, as opposed to occasional. Records demonstrate the supervisors were overseeing operations.

The Court also found the Sheriff did have a release policy. In conclusion, it was found that the fact the plaintiffs were not released in a timely fashion is bad. Mistakes were made. But, no one is entitled to an error-free bureaucracy. Since the Court found there was no deliberate indifference, the court order was affirmed. See: West v. Tillman, 496 F. 3d 1321 (11th Cir 2007).

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Related legal case

West v. Tillman