Janice Washington v. City of St. Louis, Missouri

Summary

**Key Legal Topics:** Qualified immunity; summary judgment burden; unverified complaint as evidence; deliberate indifference (42 U.S.C. § 1983); wrongful death (Mo. Rev. Stat. § 537.080); municipal liability (Monell); interlocutory appeal; collateral order doctrine. **Holding:** The Eighth Circuit vacated the district court's denial of summary judgment to three jail guards in a § 1983 deliberate-indifference and wrongful-death action. The district court committed two legal errors: (1) it required the defendants to produce evidence affirmatively defeating the plaintiff's claims, rather than allowing them to point to an absence of evidence supporting those claims under *Celotex*; and (2) it relied on unsworn allegations from the plaintiff's unverified complaint to create genuine issues of material fact, which is impermissible at summary judgment. The case was remanded for further proceedings consistent with the correct standard.

Holdings

1. A party moving for summary judgment need not produce evidence showing absence of genuine issue; it may discharge its burden by pointing out absence of evidence supporting nonmoving party's case.
2. A party may not resist summary judgment by reference only to its pleadings; district courts should not rely on unverified complaints to deny summary judgment.

Questions Presented

1. Whether the district court applied the correct summary-judgment standard under Celotex.
2. Whether the district court erred by relying on an unverified complaint as evidence at summary judgment.

Disposition

vacated