Althof v. Hanlin

Summary

The Ninth Circuit affirmed summary judgment for jail officers on an inmate’s claims arising from the denial of outdoor exercise. The court held that the officers were entitled to qualified immunity because the asserted Eighth Amendment right was not clearly established, and that the inmate had not shown the intent required for an intentional infliction of emotional distress claim.

Holdings

1. The defendants were entitled to qualified immunity because Althof's asserted constitutional right to outdoor exercise under the circumstances was not clearly established at the time of the alleged violation.
2. Summary judgment was proper on the intentional infliction of emotional distress claim because Althof presented no evidence that the defendants intended to cause him severe emotional distress.

Questions Presented

1. Whether the defendants were entitled to qualified immunity on Althof's § 1983 claim alleging that deprivation of outdoor exercise violated the Eighth Amendment.
2. Whether summary judgment was proper on Althof's intentional infliction of emotional distress claim because he lacked evidence of the defendants' intent to cause severe emotional distress.

Disposition

affirmed