Latest Case: King v. Pridmore (Civil Rights)

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King v. Pridmore

Docket: 18-14245

Opinion Date: June 5, 2020

Judge: Vinson

Areas of Law: Civil Rights, Constitutional Law

Plaintiff filed a 42 U.S.C. 1983 action against three police officers after plaintiff was shot and seriously injured while he was assisting the police apprehend a fugitive. Plaintiff alleged a section 1983 claim for involuntary servitude under the Thirteenth Amendment to the U.S. Constitution and a violation of substantive due process under the Fourteenth Amendment, as well as claims for negligence, wantonness, failure to train/supervise, and false imprisonment under Alabama state law. In this case, the officers told plaintiff that they would "throw some charges on [him]" if he did not agree to participate in a ruse to capture the fugitive. Plaintiff claimed that the threat of physical violence is what ultimately overcame his will and forced him to participate in the ruse. The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the officers based on qualified immunity, holding that the officers did not violate the Thirteenth or Fourteenth Amendment. Even assuming that there was a constitutional violation, the court held that it was not clearly established at the time that all objectively reasonable officers in their position would have known that what they said to plaintiff violated the Constitution's prohibition against involuntary servitude or its "nebulous" doctrine of substantive due process. Likewise, the court held that the officers are entitled to discretionary-function immunity on the state law claims.