Brockler v. Turner

Citations

• 2025 Ohio 2367

Syllabus

Summary judgment; foreseeable; risk of harm; handcuffed; Political Subdivision Tort Immunity Act; R.C. 2744.03(A)(6); employee; reckless and wanton; policy. Trial court did not err in granting summary judgment in favor of sheriff deputies because the risk of harm to the attorney in the courtroom by his inmate-client was not foreseeable and a violation of a departmental policy is not per se reckless. Moreover, the deputies are entitled to immunity because the plaintiff failed to satisfy his reciprocal burden of demonstrating that a genuine issue of material fact exists regarding whether the deputies acted recklessly or wantonly when the inmate was handcuffed in front of his body and by failing to anticipate the inmate's behavior during sentencing.