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.
143704P.pdf 12/09/2015 S.M. v. Michael Krigbaum
U.S. Court of Appeals Case No: 14-3704
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Loken, Author, with Beam and Shepherd, Circuit Judges]
Civil Case - civil rights - qualified immunity. The denial of qualified
immunity to sheriff on claim of failure to train or supervise is reversed,
as there was no evidence sheriff received notice of a pattern of
unconstitutional acts and conduct he observed fell far short of a pattern
of conduct that violated substantive due process; district court also
erred in ignoring admission that sheriff lacked actual knowledge of facts
necessary to show he was deliberately indifferent. In addition, sheriff
could not be deliberately indifferent in failing to satisfy a duty he did
not know he had. Sheriff had no information that would have raised an
inference that officer was violating his training and duties as a police
officer. Failure to enforce a call-in policy did not give rise to an
unconstitutional condition.