Civil Rights Appellate Clinic Secures Win for Client in Eleventh Circuit Appeal

Minnesota Law's Civil Rights Appellate Clinic secured a win in the U.S. Court of Appeals for the Eleventh Circuit today in a case denying qualified immunity to prison officers and their supervisors for violations of the Eighth Amendment that enabled Andrew Campbell, a young veteran with severe mental health issues, to take his own life while he was being held in solitary confinement and subject to suicide protocol.

In a per curiam opinion, Chief Judge William Pryor and Judges Robin Rosenbaum and Jill Pryor affirmed the district court's decision denying qualified immunity at the motion to dismiss stage. With respect to Appellant Warren Baltes, who was on duty the night of Campbell's death, the court held that "[t]aking Garner’s allegations as true, Baltes was deliberately indifferent toward Campbell’s safety because, although he knew that Campbell had severe mental health needs and posed a high risk of self-harm, Baltes did not perform even cursory supervision on the night of Campbell’s death." The court further held that "[o]ur caselaw clearly established when the suicide occurred that, when an officer fails to protect an inmate who poses a serious risk of suicide and that failure amounts to deliberate indifference, the officer violates the prisoner’s constitutional right."

With respect to the six supervisory official appellants, the court held that the "complaint alleges a causal connection between the supervisors’ conduct and [the on-duty guards'] deliberate indifference. It alleges that the inmate suicide rate in Georgia prisons—involving at least 125 suicides since 2017—was double the national average due to severe understaffing, high turnover, poor training, lack of supervision, abuse of solitary confinement, and failure to discipline officers. The supervisors allegedly knew about but failed to correct these widespread abuses." As a result, "the district court did not err by denying them qualified immunity at this stage." 

The Civil Rights Appellate Clinic represented the appellee, Krysten Garner, who filed a civil rights lawsuit under 42 U.S.C. section 1983 on behalf of Campbell's estate and his minor child. The Minnesota Law students who worked on the case were 3Ls Tyler Blackmon, Philip de Sa e Silva, Earl Lin, Ciara McManus, and Isabel Park. They were supervised by the clinic's director, Professor Elizabeth Bentley, and collaborated with attorney Eric Fredrickson of the Harman Law Firm in Atlanta, Georgia.