Boyer-Gladden v. Hill

Summary

The Wyoming Supreme Court reviewed summary judgments arising from the alleged sexual assault of a pretrial detainee by a detention deputy. The court affirmed summary judgment on the Wyoming Governmental Claims Act and state-law tort claims, affirmed judgment for the sheriff on the federal civil-rights claim, and reversed judgment for the deputy on the § 1983 claim because it was sufficiently pleaded as a personal-capacity action. The case addresses governmental immunity, statutory limitations, scope of duties, and municipal liability under § 1983.

Holdings

1. The claims against the deputy under the Wyoming Governmental Claims Act were time-barred because, under W.R.C.P. 3(b), the action was not commenced until the deputy was served, which occurred more than one year after the claim was presented to the governmental entity.
2. Summary judgment for the deputy was proper because the complaint pleaded the intentional-infliction-of-emotional-distress claim under the Wyoming Governmental Claims Act and the court would not speculate that a separate personal tort claim had also been intended.
3. The complaint sufficiently pleaded a personal-capacity § 1983 claim against the deputy. Proof of a county or sheriff's-office policy or custom was therefore not required to establish the deputy's personal liability, and summary judgment for the deputy on that ground was erroneous.
4. The sheriff was entitled to summary judgment on the state-law tort claims because the deputy's sexual conduct was outside the scope of his duties, and the record contained no evidence that the sheriff negligently hired, trained, supervised, or established rules concerning the deputy.
5. The sheriff was entitled to summary judgment on the official-capacity § 1983 claim because there was no evidence that a county or sheriff's-office policy or custom caused the alleged constitutional violation.

Questions Presented

1. Whether summary judgment was proper on Boyer-Gladden's Wyoming Governmental Claims Act claims based on the Act's claim-presentment and commencement limitations periods.
2. Whether summary judgment was proper for the deputy on the state-law tort claims pleaded under the Wyoming Governmental Claims Act.
3. Whether the deputy was entitled to summary judgment on the 42 U.S.C. § 1983 claim because the claim was treated as an official-capacity claim requiring proof of a governmental policy or custom.
4. Whether the sheriff was entitled to summary judgment on the state-law tort claims, including claims based on alleged supervisory or nondelegable duties.
5. Whether the sheriff was entitled to summary judgment on the official-capacity § 1983 claim for lack of evidence of a county or sheriff's-office policy or custom causing the alleged violation.

Disposition

reversed_and_remanded