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124000P.pdf 05/20/2014 Cody Walton v. Robert Dawson
U.S. Court of Appeals Case No: 12-4000
U.S. District Court for the Eastern District of Missouri - Hannibal
[PUBLISHED] [Riley, Author, with Bye and Gruender, Circuit Judges]
Civil case - Civil rights. In an action alleging defendants failed to
protect plaintiff, a pretrial detainee from sexual assault by another
inmate, plaintiff's failure-to-train and supervise claims must be judged
by the subjective deliberate indifference standard set out in Farmer v.
Brennan, 511 U.S. 825 (1994); the district court did not err in denying
the jail administrator's motion for summary judgment based on qualified
immunity on plaintiff's claim that the administrator failed to train a
deputy with respect to the jail's policy regarding the overnight locking
of cell doors; the court erred in denying the sheriff's motion for summary
judgment as there was nothing in the record to rebut his testimony that he
did not know of the substantial risk created by the jail administrator's
failure to train the deputy regarding door locking. Judge Gruender,
concurring in part and dissenting in part.