Anthony R. Wilson, II v. Blake Sellers, et al.

Summary

The court denied Defendants’ motion for summary judgment in a 42 U.S.C. § 1983 action brought by a pretrial detainee challenging a lockdown and loss of privileges at Madison County Jail. The court held that a reasonable jury could find the approximately 30-day lockdown was punitive rather than a security measure and that Plaintiff was not given constitutionally required notice and an opportunity to be heard. The court also rejected arguments concerning personal involvement, qualified immunity, and the absence of physical injury.

Holdings

1. Summary judgment was not warranted because a reasonable jury could find that the lockdown and loss of privileges became punitive rather than remaining a security measure, and Wilson was entitled to notice and an opportunity to be heard before being subjected to a punitive lockdown.
2. Summary judgment was not warranted on the ground that Schmidt and Sellers lacked personal involvement because the evidence permitted an inference that each participated in imposing or extending the lockdown.
3. Defendants were not entitled to qualified immunity at summary judgment because it was clearly established that a pretrial detainee could not be placed in a punitive lockdown without notice and an opportunity to be heard.
4. The absence of physical injury did not bar nominal or punitive damages for the alleged constitutional violation, although 42 U.S.C. § 1997e(e) barred compensatory damages for mental or emotional injury absent physical injury.

Questions Presented

1. Whether defendants were entitled to summary judgment on Wilson's Fourteenth Amendment claim because the lockdown was a security measure rather than punishment requiring procedural due process.
2. Whether the record established that defendants Schmidt and Sellers lacked personal involvement in imposing or extending the lockdown.
3. Whether defendants were entitled to qualified immunity because the right to notice and an opportunity to be heard before a punitive lockdown was not clearly established.
4. Whether the absence of physical injury barred Wilson's recovery of damages under 42 U.S.C. § 1997e(e).

Disposition

other