Eighth Circuit Lets Missouri Guard Skate For Placing Avowed Enemies In Same Cell, Resulting In Assault
Missouri prisoners beware: On November 19, 2024, the U.S. Court of Appeals for the Eighth Circuit reversed denial of qualified immunity (QI) to a prison guard who placed two “avowed enemy” prisoners in the same cell, precipitating an assault.
In July 2022, prisoner Robert J. Hall submitted to state Department of Corrections (DOC) staff an “Enemy Listing/Protective Custody Declaration,” which specified that Hall “felt threatened and endangered by a fellow inmate, Ahmad Townsend.” A week later, guard Paul Woodruff—not the staff member who received the declaration—placed Townsend in Hall’s cell while Hall slept. Townsend then attacked him, “causing mental and physical injuries.”
Hall sued DOC and Woodruff pro se, alleging that the guard violated DOC policy requiring “enemy declarations be checked, and/or other specific safeguards … taken, by corrections officers to ensure that declared enemies do not physically encounter one another, particularly without supervision,” his complaint recalled. More specifically, the prisoner added, policy held that “declared enemies are not to be put into the same cell together.” Woodruff’s failure to follow policy, he said, resulted in his injuries.
The federal court for the Western District of Missouri noted that, “[I]n Missouri, the doctrine of official immunity ‘protect[s] public employees from liability for alleged acts of negligence committed during the course of their official duties for the performance of discretionary acts,’” quoting Letterman v. Does, 859 F.3d 1120 (8th Cir. 2017). In its ruling, that court said that immunity thus applies to a claim arising from a public official’s discretionary acts but does not apply to a claim arising from “ministerial” or “clerical” acts.
Applying these principles to Woodruff’s motion for summary judgement, the district court found that the guard’s inaction “constitute[d] a violation of a ministerial duty imposed by department regulation and policy sufficient to survive a motion to dismiss under Rule 12(b)(6) on official-immunity grounds.” Woodruff objected to this and filed an interlocutory appeal.
On review, the Eighth Circuit noted that, according to the state Supreme Court, “[t]he central inquiry” for determining the type of act in question “is not whether the law confers a duty to act but, instead, whether the public official retains any discretion in completing [the] act,” pointing to State ex rel. Love v. Cunningham ex rel. Ludwick, 689 S.W.3d 489 (Mo. 2024).
In this case, the appellate Court decided—contrary to the district court’s assessment—that Woodruff’s inaction was a violation of a discretionary duty rather than a ministerial one. “The policy’s mandate that ‘enemy declarations be checked, and/or other specific safeguards are taken’ does not state when they must be checked or how often,” the Court noted. And “when even slight discretion exists, the duty is not ministerial,” per State ex rel. Morales v. Alessi, 679 S.W.3d 467 (Mo. 2023).
Because Woodruff retained some discretion in carrying out the policy, he was therefore entitled to QI, the Court said. Accordingly, the district court’s decision was reversed, and the case remanded. Before the Court, Hall—who had proceeded pro se—was represented by attorneys John D. James of James Law Group in St. Peters and the Law Office of Christopher R. Hays in Milwaukee. See: Hall v. Woodruff, 121 F.4th 1155 (8th Cir. 2024).
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Related legal case
Hall v. Woodruff
| Year | 2024 |
|---|---|
| Cite | 121 F.4th 1155 (8th Cir. 2024) |
| Level | Court of Appeals |