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Denial of Qualified Immunity Requires Detailed Order

The Eighth Circuit Court of Appeals remanded an Arkansas federal district court’s order denying US. Marshals qualified immunity on summary judgment.

At issue was a lawsuit brought by James Clayton Solomon, who was transferred from the Oklahoma City Federal Transfer Center to the Marshal’s office in Fort Smith, Arkansas, on April 24, 2008.  The same day, Solomon was transferred to the Benton County Criminal Detention Center (BCCDC).

Solomon’s complaint alleged U.S. Marshals Susan Jones and Cory Thomas  housed him at BCCDC in retaliation for a letter he had written against a judge, taunted him during the transfer and arranged for him to receive adverse treatment at BCCDC.

Jones and Thomas moved for dismissal or summary judgment on qualified immunity grounds.  The Arkansas federal district court denied motions and an appeal ensued.

The Eighth Circuit found “the complete absence in the order of any explicit reference to, or analysis of, Jones’ and Thomas’s claims of qualified immunity leaves us unable to determine whether the district court even considered the issue of qualified immunity before denying the motions for summary judgment.”

The district court’s order was vacated and the matter remanded for a more detailed consideration.  See:  Solomon v. Petray, 699 F.3d 1034, 1037 n.2 (8th Cir. 2012).

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Related legal case

Solomon v. Petray