Shawn Manning v. C.J. Ryan

Summary

In a § 1983 action, the Eighth Circuit affirmed qualified immunity for jail officials who enforced a blanket policy barring pretrial detainees from visitation by minor children, because the right to family visitation was not clearly established at the time. However, the court prospectively held that prison officials who permanently or arbitrarily deny an inmate visits with family members violate the constitutional right to intimate association under Turner v. Safley and Overton v. Bazzetta. The decision clarifies that such blanket restrictions may be unconstitutional going forward, but qualified immunity protected the defendants from liability for past conduct.

Holdings

1. The defendants were entitled to qualified immunity because the right to visitation with minor children was not clearly established at the time of the challenged conduct.
2. Prison officials who permanently or arbitrarily deny an inmate visits with family members, in disregard of the factors described in Turner v. Safley and Overton v. Bazzetta, violate the Constitution.

Questions Presented

1. Whether the defendants were entitled to qualified immunity for enforcing a blanket policy barring minor child visitation, given that the right to such visitation was not clearly established at the time.

Disposition

affirmed