Eleventh Circuit Upholds Dismissal of Six Female Alabama Jail Detainees’ Sexual Assault Suit
by Matt Clarke
On October 17, 2025, the United States Court of Appeals for the Eleventh Circuit upheld a district court’s summary dismissal of a federal civil rights suit brought by six women who were allegedly sexually assaulted while incarcerated at an Alabama jail because the lawsuit failed to include the person who committed most of the alleged sexual assaults as a defendant or prove that supervisory staff knew about the incidents.
Some lawsuits are lost because of bad facts; others because of bad lawyering; and still others, like this instant case, have a good bit of both. According to court documents, Stacy Bridges, Charity Tessener, Jessica Rainer, Whitley Goodson, Megan Dunn, and Allison Mann were sexually assaulted by then-jailer Rusty Boyd while they were incarcerated at the Jasper City Jail in 2017. Then-jailer Dennis Buzbee also allegedly sexually assaulted Bridges.
The women filed separate federal civil rights complaints that the district court consolidated. However, the complaints named only Jasper Police Chief J. C. Poe, Jr., Jail Supervisor Deborah Johnson, Buzbee, and the City of Jasper, Alabama, as defendants. The district court granted defendants’ motion for summary judgment because: Rainer and Mann filed their complaints after expiration of the statute of limitations; no evidence showed that Poe or Johnson were aware of the sexual assaults; there was a policy against jail staff having sex with prisoners; and no complaint had named Boyd as a defendant. Aided by attorneys Andrew Clay Allen, James Franklin Ozment, Michele E. Pate, and Raymond Andrew Garrison, plaintiffs appealed.
The Eleventh Circuit conducted a de novo review. It concluded that the claims made by Rainer and Mann were time barred as they filed them more than two years after being released from jail and thus after the two-year statute of limitations had expired. Further, Bridges failed to properly serve Buzbee, so it upheld the dismissal of the claims against him.
The Court held that plaintiffs had submitted no proof that Poe or Johnson were aware of the sexual assaults against them. There was some evidence that Johnson might have been told about a single accusation of sexual assault against another jailer but this was insufficient to establish a pattern, practice or policy of supervisory personnel tolerating sexual assaults on prisoners. which was necessary to establish supervisory liability.
Plaintiffs alleged that jailers and prisoners came up with a scheme of trading sex for being made a trustee. Some jailers then took this a step further, making women they wanted to have sex with trustees and then forcing their attentions upon them. Unfortunately, they failed to submit proof that supervisory personnel knew about this scheme. The only submissions by plaintiffs through the jail’s kiosk system dealt with minor or general complaints and administrative matters. None mentioned sexual assault.
Plaintiffs alleged the jail had no policy forbidding jailers from having sex with prisoners. The Court found that this was untrue as the jail’s employee manual specifically prohibited jailers from having sex with or sexual harassing prisoners. Further, they were trained on the policy which would have been “obvious to all without training or supervision” and thus cannot support liability, the Court said. See: Christmas v. Harris County, 51 F.4th 1337 (11th Cir. 2022).
The Court noted that supervisory liability “is demanding” and requires “subjective awareness of a substantial risk of harm to the inmate.” See: Piazza v. Jefferson County, 923 F.3d 947 (11th Cir. 2013). Because plaintiffs failed to show Poe or Johnson knew about “multiple incidents or multiple reports of prior misconduct by a particular employee,” the supervisory liability claims failed. This similarly doomed the claim of municipal liability. The dismissal was upheld. See: Bridges v. Poe, 155 F.4th 1302 (11th Cir. 2025).
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
Related legal case
Bridges v. Poe
| Year | 2025 |
|---|---|
| Cite | 155 F.4th 1302 (11th Cir. 2025) |
| Level | Court of Appeals |