Ellis White v. Leon Lott and Katelyn Jasak

Summary

The United States District Court for the District of South Carolina adopts the magistrate judge’s Report and Recommendation and grants Defendants’ motion for summary judgment. The court holds that Defendant Jasak is entitled to qualified immunity on the plaintiff’s § 1983 claims, Defendant Lott has Eleventh Amendment immunity on the state-law claims, and non-SCTCA claims against Jasak are barred by the South Carolina Tort Claims Act’s exclusivity provision. The state-law claims against Lott are dismissed without prejudice.

Holdings

1. Jasak was entitled to qualified immunity because White did not show that her conduct violated a clearly established constitutional right. The record did not establish that Jasak knew of the family-court ruling or that a reasonable officer would have understood that she was constitutionally required to discover it before seeking the arrest warrant.
2. Lott was entitled to Eleventh Amendment immunity from White's state-law claims in federal court. The sheriff's department's self-insured status did not establish that the State's treasury could not be affected, and defendants' participation in discovery did not constitute a voluntary waiver of immunity.
3. The South Carolina Tort Claims Act provided the exclusive remedy for claims against Jasak arising from conduct within the scope of her employment, and White failed to produce evidence supporting a statutory exception for actual fraud, actual malice, intent to harm, or a crime involving moral turpitude. Jasak was therefore entitled to summary judgment on the state tort claims, including false arrest or false imprisonment.
4. The district court found no clear error in the Report and conducted de novo review of the portions to which White specifically objected, adopted the Report and Recommendation, and granted defendants' motion for summary judgment.

Questions Presented

1. Whether defendant Jasak was entitled to qualified immunity on White's § 1983 claims based on her failure to discover and disclose the family-court ruling before obtaining an arrest warrant and participating in the bond proceeding.
2. Whether defendant Lott was protected by Eleventh Amendment immunity from White's state-law claims despite the sheriff's department's self-insured status and defendants' participation in discovery.
3. Whether the South Carolina Tort Claims Act provided the exclusive remedy for state tort claims against Jasak acting within the scope of employment, and whether the evidence supported an exception for actual fraud, actual malice, intent to harm, or a crime involving moral turpitude.
4. Whether defendants were entitled to summary judgment on all claims.

Disposition

other