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Eighth Circuit Affirms Denial of Immunity to Prison Guard Sued for Calling Prisoner a "Snitch"

On December 16, 2014, the Eighth Circuit U.S. Court of Appeals ruled that a federal district court judge in Alabama correctly denied a motion for summary judgment to a state prison lieutenant who was sued after he called a prisoner a "snitch" in front of other prisoners. The lieutenant had claimed that the doctrine of qualified immunity protected him from suit because the law was not clear at the time that his alleged actions violated the prisoner’s constitutional rights but the district court, and the Eighth Circuit, disagreed.

Alabama state prisoner Marvin Reeves brought the 42 U.S.C. § 1983 suit against Lt. Jacob King of the Ouachita River Unit in Malvern, Alabama. Reeves was housed in segregation when he tried to start a conversation with Lt. King and another guard when they made their rounds. King responded by telling Reeves, "Go ahead and snitch to the major like you did to him on the nurse." That nurse had recently been caught bringing contraband into the facility. Because Lt. King made his comment in front of other prisoners who knew of the nurse's situation, Reeves claimed in his lawsuit that his safety was in danger and he suffered emotional distress. The following day, Reeves was moved to another prison.

Lt. King moved for summary judgment based on qualified immunity, which the district court denied. Lt. King then filed an interlocutory appeal, which the Eighth Circuit accepted, then upheld the district court's ruling.

The appellate court first noted that it is well-settled that the Eighth Amendment binds prison officials to take reasonable measures to protect the safety and security of prisoners, including by the hand of other prisoners. Other Eighth Circuit cases in effect at the time of the alleged conduct "clearly established that labeling an inmate a snitch" in front of other prisoners violates a guard's "duty to protect an inmate from harm" and violates the constitution. See: Irving v. Dormire, 519 F.3d 441, 450 (8th Cir. 2006).

Lt. King, however, argued that those cases concerned situations where the prisoner snitched on other prisoners, not on prison staff, and are thus inapplicable. But the Eighth Circuit said the proper focus is not on who the prisoner informed on, but whether, in this case, Reeves "acted in contravention of the interests of other inmates." By exposing the prison nurse who was bringing in contraband to prisoners, Reeves actions did just that and it is thus presumed that Lt. King knew that labeling Reeves a snitch would expose him to harm from others.

The district court properly held that there were disputed material facts that precluded summary judgment, and taken in a light most favorable to Reeves, those facts subjected him "to the threat of substantial risk of serious harm at the hand of" fellow prisoners, the court found. "Accordingly, the district court properly denied qualified immunity to Lt. King." See: Reeves v. King, No. 13-3416 (8th Cir. 2014).


 

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