* court: federal (Ninth Circuit)
* public agency: California Department of Corrections
* plaintiffs' job classes: correctional officers
* trial court's decision: against defendants
* Ninth Circuit's decision: in favor of defendants
* issue area: qualified immunity, prison
Jeffers Facts
*
On September 27, 1999, a major racial disturbance occurred at the
state prison in Sacramento. Hispanic
inmates attacked black inmates. About 150-200 inmates were involved. The disturbance lasted 30 minutes and was one of the largest
disturbances in CDC history. Correctional
officers used batons, pepper spray, .37 mm launchers, and mini-14
rifles.
*
Fourteen inmates and staff were hospitalized.
One inmate was killed. Plaintiff
Jeffers was shot in the neck.
*
Correctional Officer Bess shot at a black inmate.
Correctional office Yerby shot at a Hispanic male who was
trying to knife a black inmate.
*
Jeffers was shot during the first 90 seconds of the disturbance while
trying to hold off a Hispanic inmate armed with a five-inch nail with
a plastic handle.
*
The CDC’s investigative unit determined that any shooting by
correctional officers during the disturbance came within CDC’s
shooting policy. It could
not be determined if Bess or Yerby, or either of them, had shot
Jeffers.
*
The DA’s office also concluded that the shooting of Jeffers was
accidental.
*
Jeffers sued the officers,
the warden, and the director of CDC, alleging a variety of
constitutional violations.
*
The district court denied the correctional officers’ motions for
qualified immunity.
* Denials of motions for qualified immunity are
appealable; the officers appealed; the Ninth Circuit ruled in their
favor.
Analysis of the Ninth Circuit's Jeffers Decision
*
The Ninth Circuit mauled the district court.
*
The general rule for qualified immunity is whether the defendant
violated a clearly established constitutional right of which a
reasonable officer would have been aware.
*
In the context of a prison, it is clearly established that, when there
is a disturbance, force can be used, including deadly force, as long
as it is “a good faith effort to maintain or restore discipline [and
not] maliciously and sadistically for the very purpose of causing
harm”. This is not a
high standard for prison officials or correctional officers to meet.
* The Ninth Circuit almost instantly concludes
that Officers Bess and Yerby fired in good faith to restore prison
security.
