Cortell D. Lockett v. Burkett

Summary

The court granted Deputy Kamrynn Burkett’s motion for summary judgment in Cortell D. Lockett’s Fourteenth Amendment failure-to-protect action. The court concluded that Lockett presented no evidence that his brief placement in a cellblock created a substantial risk of serious harm, that Burkett failed to take reasonable protective measures, or that her conduct caused any injury.

Holdings

1. Summary judgment was warranted for Deputy Burkett because Lockett presented no evidence establishing that Burkett's conduct placed him at substantial risk of serious harm, that she failed to take reasonable available measures to abate the risk, or that her conduct caused an injury.
2. To establish a viable Fourteenth Amendment failure-to-protect claim, a pretrial detainee must provide evidence that the defendant intentionally decided the conditions of confinement, those conditions created a substantial risk of serious harm, the defendant failed to take reasonable available measures to abate the risk despite the obviousness of the high degree of risk, and that failure caused the plaintiff's injuries.

Questions Presented

1. Whether summary judgment was proper on Lockett's Fourteenth Amendment failure-to-protect claim against Deputy Burkett.
2. Whether the undisputed evidence showed that Burkett placed Lockett at substantial risk of serious harm, failed to take reasonable available measures to abate that risk, and caused an injury.

Disposition

other