Bob Johnson, Individually and in His Official Capacity as Sheriff of Santa Rosa County, Florida v. Jessica N. Rogers, as Personal Representative of the Estate of Jose F. Escano-Reyes and as Parent and Natural Guardian of Y. C., a Minor
SocialSecurity DueProcess JusticiabilityDoctri
Where a jury exonerates jail deputies of all 42 U.S.C. §1983 claims for deliberate indifference to risk of an inmate's suicide, does the jury's finding as to the deputies foreclose liability for deliberate indifference against the Sheriff employing the deputies under Monell v. New York City Dept. of Social Services given this Court's holding in City of Los Angeles v. Heller that 'neither Monell ... nor any other of our cases authorizes the award of damages against a municipal corporation based on the actions of one of its officers when in fact the jury has concluded that the officer inflicted no constitutional harm?
QUESTIONS PRESENTED 1. Where a jury exonerates jail deputies of all 42 U.S.C. §1983 claims for deliberate indifference to risk of an inmate’s suicide, does the jury’s finding as to the deputies foreclose liability for deliberate indifference against the Sheriff employing the deputies under Monell v. New York City Dept. of Social Services given this Court’s holding in City of Los Angeles v. Heller that “neither Monell ... nor any other of our cases authorizes the award of damages against a municipal corporation based on the actions of one of its officers when in fact the jury has concluded that the officer inflicted no constitutional harm”? 2. Are the circuit courts of appeal for the Second, Third, Eighth, and Tenth Circuits unlawfully limiting this Court’s direction in Heller when those courts sometimes allow Monell liability against a government agency even where it has been determined that no agency employee committed an underlying constitutional violation? 3. Even if those circuits are correct in so-limiting Heller, has the Eleventh Circuit in this case broadened the limitation to the point that it flatly disobeys Heller? 4. Whether, in citing jail practices which had never been declared unconstitutional nor previously resulted in an inmate’s suicide, the circuit court in this case substituted hindsight analysis of negligence for evidence of deliberate indifference by the Sheriff to a suicide risk?