Westmoreland v. Brown

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a sheriff was not liable for a deputy’s actions in organizing an attack on another inmate because the deputy did not organize the attack under the pretense that he had the authority to do so
• explaining that under the Fourteenth Amendment, “a particular condition constitutes punishment only where it causes physical or mental injury” (emphasis in original)
• holding sheriff was not liable for conduct of deputy who was not acting “under color of office”
• observing that claims raised by pretrial detainees are analyzed under the Due Process Clause of the Fourteenth Amendment whereas claims raised by sentenced inmates are analyzed under the Eighth Amendment
• observing that, “punishment, whether for a convicted inmate or a pretrial detainee, is the product of intentional action, or intentional inaction, respecting known and substantial risks of harm.” (citing Farmer, 511 U.S. at 837-38)
• dismissing Section 1983 complaint on Rule 12(b)(6) motion because plaintiff could prove no facts in support of alleged causal connection

Source: CourtListener parenthetical corpus (CC0).