William Scott Sloan v. Sheriff Dwayne Burgess et al.

Summary

The United States District Court for the Southern District of Indiana granted Defendants' renewed motion for summary judgment in William Scott Sloan's Fourteenth Amendment failure-to-protect action arising from an assault by another detainee at the Johnson County Jail. The court concluded that Sloan's decision to confront the other detainee was an unforeseeable superseding cause of his injuries and that no reasonable jury could find the defendants caused them. The court denied the defendants' original summary-judgment motion as moot and directed corrections to two defendants' names.

Holdings

1. Even assuming that one or more defendants acted objectively unreasonably regarding a risk to Sloan, summary judgment was proper because no reasonable jury could find that defendants caused Sloan's injuries. Sloan's voluntary decision to confront Lewis was an unforeseeable superseding cause that severed defendants' liability.
2. The claim requires an intentional decision concerning the conditions of confinement, conditions creating a substantial risk of serious harm, failure to take reasonable available measures that a reasonable officer would have appreciated were necessary, and causation of injury. Unlike an Eighth Amendment claim, the detainee need not prove subjective awareness of the substantial risk, but negligence is insufficient.
3. Spoliation sanctions were inappropriate because Sloan did not show that defendants had a duty to preserve the additional footage or that it was destroyed in bad faith.

Questions Presented

1. Whether defendants were entitled to summary judgment on Sloan's Fourteenth Amendment failure-to-protect claims because Sloan could not establish causation.
2. Whether the preserved video evidence conclusively contradicted Sloan's account of the altercation and established that his own conduct caused the injuries.
3. Whether the failure to preserve additional surveillance footage warranted spoliation sanctions.
4. Whether portions of a defendant's declaration containing statements by nonparties should be excluded as hearsay.

Disposition

other