finding insufficient evidence to create a genuine issue of material fact on a claim of failure to investigate where plaintiff produced no evidence that any similar incidents of holding an inmate beyond his date of release had ever been reported to the current or any former sheriff
How later courts described this case
- finding insufficient evidence to create a genuine issue of material fact on a claim of failure to investigate where plaintiff produced no evidence that any similar incidents of holding an inmate beyond his date of release had ever been reported to the current or any former sheriff
- allowing the plaintiff to proceed with his official-capacity claim—which the Court acknowledged was actually against the County—because the plaintiff, in his “inartful pleadings” (Id. at 51), did not assert the same claim against the County as he did against the official
- collecting cases and noting that the right is established both via the Due Process Clause of the Fourteenth Amendment and the Cruel and Unusual Punishment Clause of the Eighth Amendment
- finding that under Tennessee law, “the Sheriff is the final policymaker over the operation of the jail”
Written by the judges who cited it.
The opinion
RALPH B. GUY, JR.,
concurring in the judgment of remand.
Although I join the other two panel members in deciding to remand this case for further proceedings, I write separately because the basis of the remand is reliance on a statutory section not relied upon or cited by the plaintiff in the district court. Prior to placing reliance on TenmCode Ann. § 8-8-201(a)(3), the court rejected every basis for reversal urged by the plaintiff in this appeal.
By joining in the judgment, I do not mean to imply that I agree that TenmCode Ann. § 8-8-201 is controlling or even relevant. The best place for this to be thrashed out, however, is in the district court where the defendant will have an opportunity to respond and the ■ district judge can make an initial evaluation of the import of this statutory section.