Punishment JusticiabilityDoctri
Whether qualified-immunity-doctrine-demands-identical-fact-pattern
QUESTION PRESENTED This Court has repeatedly held that government officials lack qualified immunity when prior decisions provide “fair warning” of constitutional violations. Hope v. Pelzer, 536 U.S. 730, 740-41 (2002). Long before the events leading to this case, the Eleventh Circuit held that correctional officers violate the Constitution by delaying medical treatment for a prisoner’s “bleeding cut” and ignoring the presence of “blood on the floor and on his coat and shirt.” Aldridge v. Montgomery, 753 F.2d 970, 972-73 (11th Cir. 1985) (per curiam). But the Eleventh Circuit held here that Aldridge failed to clearly establish the unconstitutionality of ignoring a prisoner’s cut that “leak[ed] blood . . . all over the place,” relying on distinctions between a “pool of blood” and a “path of blood,” as well as between a cut above the right eye and a similarly sized cut to the right hand. The question presented is: Whether this Court’s qualified immunity doctrine demands a nearly identical fact pattern before a case can clearly establish the law—as the Eleventh and Fifth Circuits have held—or whether a case can provide “fair warning” despite some factual variation—as the First, Second, Third, Fourth, Sixth, Seventh, Eighth, Ninth, and Tenth Circuits have held.