Stark v. Lee Cnty.

993 F.3d 622

Jaymes Anthony STARK, Plaintiff - Appellee

v.LEE COUNTY, IA; State of Iowa, Defendants

Steve Sproul, Defendant - Appellant

Jeremy Hamelton; Zachary Coppage; Dustin Young; C.J. Wray, Defendants

National Association for Public Defense; Rights Behind Bars, Amici on Behalf of Appellee

No. 20-1606

United States Court of Appeals, Eighth Circuit.

Submitted: January 12, 2021

Filed: April 7, 2021

David A. O'Brien, Dave O'Brien Law, Cedar Rapids, IA, for Plaintiff - Appellee.

Steven Eugene Ort, Bell & Ort, New London, IA, for Defendant - Appellant Steve Sproul.

Samuel David Kinder Weiss, Washington, DC, for Amici on Behalf of Appellees.

Before COLLOTON, WOLLMAN, and SHEPHERD, Circuit Judges.

WOLLMAN, Circuit Judge.

Lee County, Iowa, Deputy Sheriff Steve Sproul appeals from the district court's denial of his qualified immunity-based motion for summary judgment. We reverse and remand.

Sproul transported Jaymes Stark from a medical appointment to the Lee County Correctional Center on June 29, 2016.¹ Stark sat in the backseat of Sproul's cruiser, restrained by leg shackles, a belly chain, and handcuffs but not by a seatbelt. While Sproul and Stark were en route, the city police dispatcher advised that an armed robbery was in progress at a nearby bank. Sproul drove to the bank with the intent of observing the crime in progress. Upon arriving, Sproul saw the robbery suspect flee on foot through a vacant lot. Sproul drove his cruiser at approximately 20 to 25 miles per hour through the lot to follow the fleeing suspect. During the pursuit, the suspect turned around and fired a handgun, striking the cruiser. In response, Sproul turned sharply to the right and drove away from the scene. Stark remained in the backseat throughout these events. Stark's shackles prevented him from bracing his body, which, when combined with his lack of seatbelt restraint, caused him to be "thrown around" as Sproul drove over ruts and depressions in the unmaintained lot. Stark immediately thereafter began to experience lower back and neck pain. Stark filed suit under 42 U.S.C. § 1983, alleging that Sproul had failed to safeguard his health and safety and had thereby inflicted injuries upon him. Stark claimed that Sproul thus subjected him to cruel and unusual punishment in violation of the Eighth Amendment.

We review de novo the district court's denial of a motion for summary judgment based on a claim of qualified immunity. Barton v. Taber, 908 F.3d 1119, 1123 (8th Cir. 2018). "At summary judgment, qualified immunity shields a law enforcement officer from liability in a § 1983 action unless: ‘(1) the facts, viewed in the light most favorable to the plaintiff, demonstrate the deprivation of a constitutional or statutory right; and (2) the right was clearly established at the time of the deprivation.’ " Id. (quoting Howard v. Kan. City Police Dep't, 570 F.3d 984, 988 (8th Cir. 2009) ).

Stark argues that Sproul was deliberately indifferent to his health and safety. "The standard applicable when determining whether prison officials unnecessarily and wantonly have inflicted pain, and thus have violated the Eighth Amendment, varies with the type of violation alleged." Howard v. Barnett, 21 F.3d 868, 871 (8th Cir. 1994). We apply the deliberate indifference standard in those situations in which "the State's responsibility to attend to the medical needs of prisoners does not ordinarily clash with other equally important governmental responsibilities." Whitley v. Albers, 475 U.S. 312, 320, 106 S.Ct. 1078, 89 L.Ed.2d 251 (1986) ; see also Ambrose v. Young, 474 F.3d 1070, 1076 (8th Cir. 2007) (applying deliberate indifference standard to officials who were "responsible for inmate safety during work assignments" because the officials were "not confronted with competing obligations or exigent circumstances").

When competing institutional concerns or obligations are present, however, the "deliberate indifference standard does not adequately capture the importance of such competing obligations[ ] or convey the appropriate hesitancy to critique in hindsight decisions necessarily made in haste, under pressure, and frequently without the luxury of a second chance." Whitley, 475 U.S. at 320, 106 S.Ct. 1078. Sproul thus contends that Stark's claim should instead be analyzed as an excessive force claim under the intent to harm standard, which is appropriate in contexts in which "a prison security measure is undertaken to resolve a disturbance ... that indisputably poses significant risks to the safety of inmates and prison staff ...." Id. at 320–21, 106 S.Ct. 1078 (internal citation omitted). Because we conclude that Sproul is entitled to qualified immunity under the deliberate indifference standard, we need not make a definitive ruling on which standard should apply. See Bailey v. Feltmann, 810 F.3d 589, 593 (8th Cir. 2016) ("We think it prudent to avoid addressing the proper constitutional standard unnecessarily.").

Stark argues that Sproul acted with deliberate indifference because there was a substantial risk of harm, the existence of which Sproul knew and disregarded when he engaged in a chase through an unmaintained field with the shackled-but-not-seat-belted Stark in the backseat. See Brown v. Fortner, 518 F.3d 552, 558–59 (8th Cir. 2008) (setting forth deliberate indifference elements). We disagree because Stark has not shown that Sproul knew of or disregarded the unmaintained condition of the rut-filled lot when he chose to follow the fleeing suspect. There is likewise no evidence that Sproul either knew of or disregarded a substantial risk that during the "really quick chase" the suspect would shoot into the patrol car and strike the windshield, radiator,...