Adkins v. Fields

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Questions Presented

1. Whether Plaintiffs were entitled to reopen discovery and stay resolution of the summary-judgment motions based on reported statements by former Sheriff Stines's criminal-defense lawyer.
2. Whether Hill's § 1983, negligence, gross negligence, assault, battery, IIED, and NIED claims were barred by limitations, unsupported by admissible evidence, or otherwise failed on the merits.
3. Whether Adkins's Fourteenth Amendment § 1983 claim against Fields presented a genuine dispute concerning consent and coercion.
4. Whether Adkins's Fourth Amendment claim against Fields was the proper constitutional theory for the alleged sexual contact.
5. Whether Fields was entitled to qualified immunity on Adkins's federal claim or qualified official immunity on her Kentucky tort claims.
6. Whether the official-capacity claims against Fields and Jones, treated as claims against the Letcher County Sheriff's Office, survived summary judgment under failure-to-train or failure-to-supervise principles.
7. Whether the Sheriff's Office was immune from Adkins's state-law claims.
8. Whether EKCS was entitled to summary judgment on Adkins's and Hill's claims.

Holdings

1. The court denied Plaintiffs' motion to reopen discovery and hold the summary-judgment motions in abeyance because the request was based on unsworn hearsay reported in an unavailable online article, the record was already fully developed, discovery had long closed, and further delay was unwarranted.
2. Hill's § 1983, negligence, gross negligence, assault, and battery claims were barred by Kentucky's one-year limitations period because the record did not genuinely dispute that the alleged injury-producing sexual contact occurred no later than December 2019, while suit was filed on January 31, 2022.
3. Hill's IIED and NIED claims did not survive summary judgment because the claims duplicated traditional tort claims for which emotional-distress damages were available, and Hill submitted no admissible, expert-supported evidence of the requisite severe or serious emotional injury.
4. Adkins's Fourteenth Amendment § 1983 claim against Fields survived summary judgment because a genuine dispute existed over whether the sexual contact was consensual and whether coercive factors—including Fields's control over Adkins's liberty, ankle monitor, and fees—rebutted any presumption of consent.
5. Adkins's Fourth Amendment claim was dismissed because the alleged sexual contact was covered by the Fourteenth Amendment and no evidence showed that the contact occurred during a search or seizure.
6. Fields was not entitled to qualified immunity at summary judgment because the genuine dispute over whether he violated Adkins's Fourteenth Amendment rights prevented the court from finding, at that stage, that no clearly established right was violated.
7. Adkins's assault and battery claims against Fields survived summary judgment because consent was disputed, but her negligence and gross-negligence theories were dismissed because the alleged conduct was intentional and negligence and assault-and-battery theories are mutually exclusive.
8. Summary judgment was denied on the argument that punitive damages were unavailable because a jury could find that the alleged nonconsensual sexual contact reflected wanton or reckless disregard for Adkins's rights.
9. Fields was not entitled to qualified official immunity on Adkins's state-law claims because he failed to make the required prima facie showing that the challenged conduct was within the scope of his discretionary authority, and the record also supported an inference of bad faith.
10. Adkins's official-capacity § 1983 failure-to-train and failure-to-supervise claims against Fields and Jones, treated as claims against the Letcher County Sheriff's Office, survived summary judgment because the record could support a finding of deliberate indifference and causation based on the Sheriff's failure to implement its own sexual-misconduct training and complaint policies.
11. The Sheriff's Office was immune from Adkins's state-law negligence, gross-negligence, assault, and battery claims because Fields's alleged sexual misconduct was motivated by personal sexual interests and was outside the scope of his employment, so KRS § 70.040 did not waive immunity.
12. EKCS was not entitled to summary judgment on Adkins's § 1983 failure-to-train or failure-to-supervise claim or her state negligent hiring, training, and supervision claim because EKCS offered no independent arguments and the court would not construct arguments for it. EKCS was entitled to summary judgment on Hill's claims and on Adkins's IIED and NIED claims for the reasons stated elsewhere.

Key quotations

Factual background

Adkins and Hill were placed on home incarceration and supervised by Ben Fields, who also worked as a court security officer. Both women alleged that Fields used his control over ankle monitors, home-incarceration fees, and potential return to jail to coerce sexual contact. Adkins presented deposition testimony, Fields's guilty plea to sex-related and monitoring offenses, and evidence concerning Letcher County Sheriff's Office training, supervision, complaint handling, and Fields's overlapping employment with EKCS. Hill had died without providing a deposition or affidavit establishing when the alleged sexual contact occurred, leaving the record tied to conduct no later than December 2019.

Procedural history

The action was filed on January 31, 2022, and Plaintiffs proceeded under a second amended complaint. After discovery closed and the summary-judgment motions were fully briefed, Plaintiffs sought to reopen discovery based on reported statements by former Sheriff Mickey Stines's criminal-defense lawyer. The court denied that request, granted EKCS's motion to join the defense motions, granted in part and denied in part the summary-judgment motions, dismissed Hill's claims in their entirety with prejudice, dismissed most of Adkins's claims with prejudice, and allowed specified claims by Adkins to proceed to trial.