Crane v. Utah Department of Corrections.
No. 20-4032. D.Utah. Judge McHugh. Eighth Amendment—Qualified Immunity—Americans with Disabilities Act—Rehabilitation Act—Supplemental State Law Claims.
October 18, 2021
Tucker had severe brain damage and impulse control disorders and was mentally and intellectually disabled. When he was 17 years old, he was sentenced to imprisonment for two to five years in the Utah Department of Corrections (UDC) for automobile theft and related offenses. Shortly thereafter he was transferred to the Central Utah Correctional Facility (CUCF). Once there, inmate disciplinary officers punished him for various nonviolent infractions, including by placing him in punitive isolation for significant periods of time. While at CUCF Tucker was diagnosed with psychosis and major depressive disorder and prescribed medications. Nevertheless, prison officials subjected him to additional punitive isolation without consulting mental health staff. Tucker committed suicide by hanging himself from the top of his bunk bed in his isolation cell.
Plaintiff is Tucker’s grandmother and the personal representative of his estate. As relevant here, she filed suit under 42 USC § 1983 in Utah state court against various CUCF and UDC officials. Defendants removed the suit to federal court. Plaintiff then filed an amended complaint alleging Eighth Amendment claims, statutory claims for violations of the Americans with Disabilities Act and the Rehabilitation Act (collectively, ADA claim), and a claim under the Utah Constitution’s Unnecessary Rigor Clause. The district court granted defendants’ motion for judgment on the pleadings on the basis of qualified immunity. Having dismissed all federal claims, the district court declined to exercise supplemental jurisdiction over the remaining state constitutional claim.
Plaintiff argued on appeal that the district court improperly dismissed the Eighth Amendment claims based on qualified immunity. To defeat a qualified immunity defense, a plaintiff must show that (1) the official violated a statutory or constitutional right, and (2) the right was clearly established at the time of the challenged conduct. The Tenth Circuit analyzed the second prong first because it was dispositive in the district court, examining whether mentally ill prisoners have a clearly established right to be free from punitive isolation. It concluded that the lines of cases plaintiff cited do not clearly establish this principle, and there is no precedential Tenth Circuit or US Supreme Court case directly on point. Further, there is no blanket case law rule against punitive isolation of mentally ill inmates or against the placement of such inmates in cells with tie off points. Here, based on the allegations in the amended complaint, the defendants’ actions did not cross a clearly established constitutional line, so plaintiff failed to satisfy the second requirement necessary to overcome qualified immunity. Accordingly, the district court erred.
Plaintiff also argued that the district court erred in dismissing the ADA claim. However, the amended complaint failed to state a claim under Title II of the ADA by not alleging that Tucker’s disability was a but-for cause of the purported discrimination, so the district court did not err.
Lastly, because it affirmed dismissal of the federal claims and plaintiff did not argue that the district court abused its discretion, the Tenth Circuit determined that the district court properly elected to forgo exercising supplemental jurisdiction over the related state law claim.
The order was affirmed.