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Vickie Fields v. Bill Abbott

August 30, 2011


Appeal from the United States District Court for the Western District of Missouri.

The opinion of the court was delivered by: Gilman, Circuit Judge.

Submitted: April 14, 2011

Before WOLLMAN, GILMAN,*fn1 and MELLOY, Circuit Judges.

In 2004, Vickie Fields was employed as a jailer in Miller County, Missouri. While at work one evening in July of that year, Fields was seriously injured by two inmates who took her hostage and attacked her after she honored their request to visit the jail's law library.

Fields filed a civil rights action against Miller County, its sheriff, three of its county commissioners, and several other defendants to recover for her injuries. All of the defendants moved for summary judgment, including the Miller County sheriff and the Miller County commissioners (collectively, the Miller County individual defendants), who asserted that they were entitled to qualified immunity. Thereafter, the district court granted summary judgment in favor of all of the defendants other than Miller County and the Miller County individual defendants.

The Miller County individual defendants have now filed this interlocutory appeal. They allege that the district court erred in concluding that a reasonable jury could find that they violated Fields's substantive due process rights. For the reasons set forth below, we conclude that the Miller County individual defendants are entitled to qualified immunity. We therefore reverse the judgment of the district court and remand the case for further proceedings against Miller County, the sole remaining defendant in this case.


The facts giving rise to this interlocutory appeal stem from injuries that Fields suffered on July 21, 2004 while working as a jailer for the Miller County Jail. Fields and two other jailers were at the jail that night when inmates Lawrence Arnold and John Reynolds requested access to the jail's law library, which was located in the drunk-tank cell. Arnold stated that he was Reynolds's "attorney." The Miller County Jail's Standard Policy and Procedures Manual specifies that inmates may "assist other inmates . . . in researching and preparing legal documents, consistent with security." It also stated that all "denials of access to the law library will be fully documented."

Fields was not aware of any policy or practice with regard to placing two inmates in the drunk-tank cell at the same time. She believed that she was required to honor the inmates' request under the jail's policy of ensuring inmates access to the law library and of allowing inmates to assist each other with legal issues. Fields acknowledges that she and one of the other jailers made the decision to put Arnold and Reynolds in the drunk tank together.

To honor their request, Fields escorted the two inmates, unhandcuffed, to the law library. She chose to move Arnold and Reynolds without handcuffs because she was allegedly told that there was no need to handcuff prisoners when transferring them within the facility.

While Arnold and Reynolds were in the law library, Reynolds asked Fields if he could use the restroom and get a drink of water. Before Fields opened the drunk-tank door, she saw Arnold and Reynolds standing near the middle of the cell. Prior to opening the door she did not give the inmates any instructions about where to stand, although she acknowledges that ordering inmates to stand away from the cell door prior to opening it was discussed in the basic-training course she had taken.

The drunk-tank door had a handle and lock on the outside, which Fields used to open the door, as well as a handle on the inside of the door that was accessible to Arnold and Reynolds. As Fields was opening the door, one of the inmates grabbed the inside handle and pulled back on the door, causing Fields to lose her balance. At that point, the inmates grabbed Fields and held her hostage. Fields alleges that, as a result of the incident, she suffered psychological trauma and underwent multiple surgeries for injuries to her back, rotator cuffs, hips, and hand.

A few months prior to the events at issue in this case, Fields was injured in a similar incident involving the same drunk-tank door. During that incident, an inmate who was attempting to commit suicide grabbed the inside handle of the door and pulled the door in on Fields. The door hit Fields twice, once catching her hand and once striking her neck. Fields reported the incident and complained that the interior drunk-tank door handle allowed inmates to gain control of the door from inside the cell.

The record also includes evidence that the Miller County Jail was understaffed, and that Sheriff Abbott knew that he did not have as many jailers working in the jail as the Missouri Department of Corrections recommended that he employ. Despite the Miller County Jail's understaffing problems, the jail still accepted inmates who were transferred from other county jails. Arnold in fact had been transferred from ...

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