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Denis Quinette v. Dilmus Reed, et al.
Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 18-10607 · judgment February 21, 2020
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Question presented
Petitioner Denis Quinette was violently attacked by a jailer at the Cobb County Jail who had a terrifying history of violence and inmate abuse.1 Despite this history, the jailer’s supervisors never suspended him in connection with inmate abuse and offered nothing other than de minimus discipline in response to clear and repeated violations of inmates’ constitutional rights. Petitioner sued the jailer’s supervisors under 42 U.S.C. § 1983 for failing to meaningfully discipline or terminate the jailer despite this history. A divided Eleventh Circuit panel granted qualified immunity to the supervisors on the theory that, while prior precedent established the unconstitutionality of a supervisor failing to meaningfully address an employee’s repeated transgressions, those cases involved zero discipline or de minimus discipline. The panel distinguished the jailer’s history because he had received some discipline in connection with other unrelated bad conduct, despite the fact that the jailer received only de minimus discipline after he attacked and abused inmates. 1 The jailer had been the subject of twelve internal affairs investigations, six of which were deemed “founded” or “sustained” and three of which involved attacking restrained inmates. Moreover, in the previous year the jailer had pursued a sustained campaign of inmate abuse including racial slurs, physical threats, religious abuse, cruel and belittling language, and abusive behavior, as well as sexual harassment of a coworker.
Counsel of record
For petitioner
Mark Andrew Begnaud
Eshman Begnaud LLC
For respondent
Lauren S. Bruce
Case
Conference history
Distributed for 1 conference
Proceedings
- Jun 01 2021Petition DENIED.
- May 11 2021DISTRIBUTED for Conference of 5/27/2021.
- Apr 19 2021Waiver of right of respondent Lynda Coker, Milton Beck, Donald Bartlett, Lewis Alder, Janet Prince, Roland Craig, Neil Warren to respond filed.
- Mar 18 2021Petition for a writ of certiorari filed. (Response due April 23, 2021)