DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
042714P.pdf 12/22/2005 Jerry Hart v. City of Little Rock
U.S. Court of Appeals Case No: 04-2714
Eastern District of Arkansas
[PUBLISHED] [Bye, Author, with Beam and Smith, Circuit Judges]
Civil case - civil rights. District court erred in denying City's motion
for Judgment as a Matter of Law as the evidence was insufficient to prove
the city violated the plaintiff police officers' civil rights when it released
their personnel records in response to a subpoena in a criminal case; the
evidence was insufficient to show the City recognized and deliberately
disregarded the substantial risk of serious harm plaintiffs contend release
of the information created, as the evidence showed at most negligence or
gross negligence, and the City's action did not rise to the level of
subjective deliberate indifference necessary to sustain a substantive due
process claim. Reversed and remanded.