Clancy v. McCabe

Summary

The Massachusetts Supreme Judicial Court reviewed the denial of summary judgment to a former Massachusetts public safety commissioner in a 42 U.S.C. § 1983 supervisory-liability action. The court held that the commissioner’s six-month unpaid suspension and referral of a state trooper to a departmental stress unit did not constitute deliberate indifference as a matter of law and that the required affirmative causal link was not shown. The court reversed and directed entry of judgment for the defendant based on qualified immunity.

Holdings

1. McCabe's six-month unpaid suspension of Rivera and order that he receive counseling through the State police stress unit did not, as a matter of law, constitute reckless, callous, or deliberate indifference to the constitutional rights of female motorists.
2. Clancy failed to establish the required affirmative link between McCabe's conduct and Rivera's later violation of her constitutional rights.
3. McCabe was entitled to qualified immunity because a reasonable official could have believed that his disciplinary and supervisory actions were lawful in light of clearly established law and the information available to him.

Questions Presented

1. Whether the evidence created a genuine issue of material fact that McCabe acted with deliberate or reckless and callous indifference to female motorists' constitutional rights.
2. Whether McCabe's actions and omissions were affirmatively linked to Rivera's later constitutional violation and Clancy's injuries.
3. Whether McCabe was entitled to qualified immunity from Clancy's § 1983 supervisory-liability claim.

Disposition

reversed