Summary
The Eleventh Circuit reviewed an interlocutory appeal from the denial of qualified immunity in a 42 U.S.C. § 1983 action arising from a sheriff’s deputy’s allegedly intoxicated, high-speed driving that resulted in a fatal collision. The court held that it lacked jurisdiction to review whether the deputy acted under color of state law, but assumed that issue for purposes of evaluating qualified immunity. It reversed the denial of qualified immunity because the alleged constitutional violation was not clearly established under Eleventh Circuit precedent.
Topics
Practice areas
Questions Presented
- Whether the Eleventh Circuit had interlocutory jurisdiction to review the district court's determination that Locure acted under color of state law.
- Whether Locure was entitled to qualified immunity where the complaint plausibly alleged that his conduct violated substantive due process but Eleventh Circuit precedent did not clearly establish that the conduct was unconstitutional.
- Whether the alleged conduct was clearly unconstitutional under the obvious-clarity method for establishing a constitutional right.
Holdings
- In an interlocutory appeal from the denial of qualified immunity, the court of appeals lacks jurisdiction to review whether the defendant acted under color of state law because that question concerns an element of the § 1983 claim, not the qualified-immunity defense.
- Locure was entitled to qualified immunity because, even assuming that his conduct violated Moss's substantive-due-process right to bodily integrity, the unconstitutionality of that particular conduct was not clearly established at the time of the alleged violation.
Key quotations
“Whether the defendant was acting under color of law is about the applicability of section 1983, not about whether he is entitled to qualified immunity.” (5-6)
“The ‘obviously clear’ inquiry, by contrast, is about the relationship of the state actor’s conduct to the state of constitutional law.” (13)
“The Constitution sets the boundaries for federal liability, not the outer limits of accountability.” (13)
Factual background
Darian Locure, an off-duty Macon County sheriff's deputy, left the sheriff's office in a police truck after becoming intoxicated. At night, without headlights or emergency lights, he drove approximately 70 miles per hour in a 25-mile-per-hour zone. His nearly invisible vehicle collided with a car carrying Edwin Moss, who died at the scene. Locure was later indicted for felony reckless manslaughter.
Procedural history
Hughes sued Darian Locure in Alabama state court, asserting three state-law wrongful-death claims and a § 1983 substantive-due-process claim. After removal to the United States District Court for the Middle District of Alabama, Locure moved to dismiss, arguing that the complaint failed to allege a clearly established constitutional violation and that he had not acted under color of state law. The district court denied the motion, concluding that Hughes plausibly pleaded a § 1983 claim and that qualified immunity did not apply. Locure died, and Monique Locure was substituted as appellant. The Eleventh Circuit reversed the denial of qualified immunity and remanded.
Remand instructions
Remand for further proceedings consistent with the opinion after reversal of the denial of qualified immunity.