Hazen v. Pasley

Summary

The Eighth Circuit reviewed consolidated actions arising from the Hazens' arrests, confinement in the Phelps County Jail, and transfer of personal property to a county sheriff. The court affirmed the denial of discovery sanctions and reversed the judgment on the property claim, holding that transfers of property by prisoners to custodial law enforcement officers violate public policy under Missouri law.

Holdings

1. Under Missouri law, a transfer of property by a prisoner in the custody of a law enforcement officer to that officer violates public policy and cannot be sustained merely because the district court found the transfer was not coerced.
2. The district court did not abuse its discretion by denying sanctions against Hensley for failing to comply with the discovery order.

Questions Presented

1. Whether, under Missouri law and public policy, a transfer of property by a prisoner to a law enforcement officer who had custodial authority over him is invalid.
2. Whether the district court abused its discretion by denying sanctions against an officer who failed to comply with a discovery order.

Disposition

reversed_and_remanded