Marilyn Donald, as next-of-kin and wrongful death representative of the late Marcus Donald, in her individual capacity, and Charles Donald, as next-of-kin and wrongful death representative of the late Marcus Donald, in his individual capacity v. Floyd Bonner, Jr., et al.

Summary

The United States District Court for the Western District of Tennessee grants Sheriff Floyd Bonner, Jr.’s and Chief Jailer Kirk Fields’ Rule 12(b)(6) motions to dismiss individual-capacity supervisory-liability claims arising from the death of a detainee in the Shelby County Jail. The court holds that the complaint does not plausibly allege that either defendant engaged in active unconstitutional behavior or personally caused the alleged constitutional violation. The court therefore concludes that both defendants are entitled to qualified immunity, while leaving unresolved whether the Eighth or Fourteenth Amendment governs the underlying failure-to-protect claim.

Holdings

1. The amended complaint did not plausibly allege that Bonner personally authorized, approved, encouraged, or knowingly acquiesced in unconstitutional conduct, or that he actively participated in the staffing procedures alleged to have caused Donald's death. General responsibility as sheriff and generalized knowledge of understaffing were insufficient.
2. The amended complaint did not plausibly allege that Fields actively authorized, approved, or knowingly acquiesced in unconstitutional conduct. Allegations that Fields created or authorized a post-classification system and inadequately allocated limited staff did not establish that he abandoned his specific duties or personally caused the alleged constitutional injury.
3. Bonner and Fields were entitled to qualified immunity at the pleading stage because the complaint failed to plausibly allege a constitutional violation attributable to either defendant through supervisory liability.

Questions Presented

1. Whether the amended complaint plausibly alleged that Sheriff Bonner personally engaged in active unconstitutional behavior or caused Donald's death through supervisory conduct.
2. Whether the amended complaint plausibly alleged that Chief Jailer Fields actively authorized, approved, or knowingly acquiesced in unconstitutional conduct through jail staffing and post-classification decisions.
3. Whether Bonner and Fields were entitled to qualified immunity because the complaint failed to plausibly allege a constitutional violation attributable to either defendant.

Disposition

other