Fifth Circuit: No Qualified Immunity for Mississippi Sheriffs in Suit Over Mentally Ill Man’s Years-long Unlawful Detention
by Matt Clarke
On August 24, 2022, the U.S. Court of Appeals for the Fifth Circuit upheld a district court’s denial of qualified immunity (QI) to the current and former sheriffs of Clay County, Mississippi, in a suit seeking to hold them liable for detaining a mentally ill man in the county jail without charges for more than 12 years.
In 2005, Steven Jessie Harris, who had a history of schizophrenia, was charged with murdering his father, shooting at three police officers and into occupied cars, carjacking and kidnapping. The trial court ordered him held without bond, and he was incarcerated at the jail.
Five years later, in 2010, a mental health evaluation determined there was “no substantial probability that [Harris could] be restored to competence to proceed legally in the foreseeable future.” So the trial court ordered Mississippi to pursue civil commitment proceedings in the chancery court, remanding Harris to be held “until the determination of said civil proceedings.” His case was then removed from the active docket.
The chancery court erroneously dismissed the civil commitment proceeding the day it was filed; citing lack of jurisdiction due to the criminal charges, it apparently was confused by the fact they were by then inactive. That same month, then-Sheriff Laddie Huffman and then-deputy — and current-Sheriff — Eddie Scott signed a “Diligence Declaration” in a separate case, stating that Harris could not be found in the county following a diligent search and inquiry. This left the trial court believing that Harris had been committed.
In 2016, the Clarion-Ledger published an article about Harris’ plight. This led the chancery court to reconsider the dismissal of his case and commit him to a mental hospital. In 2017, he was released from the facility to his family for outpatient mental health care because the state had insufficient bedspace for long-term commitments.
With the aid of local attorney Carlos E. Moore, Harris’ mother then filed a federal civil rights lawsuit in federal court for the Northern District of Mississippi, seeking to hold the county, Huffman and Scott liable for her son’s unlawful detention. She also alleged that Huffman’s forcible medication of Harris violated the detainee’s Fourteenth Amendment rights.
Defendants filed for summary judgment, claiming QI. But the district court found that they were not entitled to QI, except for Huffman on the forced medication claim. Defendants filed an interlocutory appeal.
Taking up the case, the Fifth Circuit held that counties could not claim QI, pursuant to Owen v. City of Independence, 445 U.S. 622 (1980). The court noted that the “Fourteenth Amendment prohibits a state from confining a criminal defendant ‘solely on account of his incapacity to proceed to trial,’” quoting Jackson v. Indiana, 406 U.S. 715 (1972).
“Harris’s prolonged detention violated Jackson,” the Court continued. “Without a chance at his competency being restored or a pending civil proceeding that could result in his commitment based on dangerousness, Harris was entitled to go free” once the competency proceeding had been dismissed.
“Yet he remained in jail for six years,” the Court recalled.
Moreover, Huffman and Scott should have known that detaining a person for so long without a pending hearing was unconstitutional, the Court continued. Also, the false declaration they signed could be evidence they concealed the unlawful detention. The sheriffs also violated the court’s order to detain Harris before the determination of the civil proceeding but only “[u]ntil that point, not longer.”
The right to be free from unlawful detention had been established for decades, the Court observed, noting Jauch v. Choctaw Cty.,874 F.3d 425 (5th Cir. 2017)— including its citation of Jones v. Jackson, 203 F.3d 875 (5th Cir. 2000). Therefore, the Court dismissed Clay County’s appeal and affirmed the denial of summary judgment to Huffman and Scott. At the Court, Moore was joined by Louisiana attorney Pride J. Doran of Doran & Cawthorne. See: Harris. v. Clay Cty., 47 F.4th 271 (5th Cir. 2022).
Defendants filed for a writ of certiorari from the U.S. Supreme Court on November 22, 2022, asking it to hear the case. PLN will update developments as they are available.
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