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Eleventh Circuit rules that Georgia jail employees are not civilly liable for pretrial detainee’s murder by fellow inmate

On June 22, 2020, in Grochowski v. Clayton County, Georgia, No. 18-14567, the Eleventh Circuit Court of Appeals affirmed a district court summary judgment in favor of the defendants’ in a § 1983 civil rights case arising from a pretrial detainee’s death at the Clayton County Jail in Georgia. The pretrial detainee was beaten to death by another inmate with whom he shared a cell. The inmate’s surviving children filed the action against the County and four jail supervisors, maintaining that their father’s due process rights were violated. The plaintiffs identified two conditions which they argued pose a substantial risk of serious harm to inmates at the jail. First, they argued that the jail’s classification process does not adequately identify inmates with violent or assaultive tendencies, which leads to nonviolent inmates being double-celled with violent inmates. Second, they argued that the jail’s practice of performing hourly rounds is insufficient to ensure the safety of inmates while they are inside their cells. The Eleventh Circuit acknowledged that “[a] prison official’s deliberate indifference to a known, substantial risk of serious harm to an inmate violates the Fourteenth Amendment,” quoting from Keith v. DeKalb Cty., 749 F.3d 1034, 1047 n.35 (11th Cir. 2014). However, the Court concluded that the plaintiffs failed to show that the jail’s classification system for assigning inmates to cells does not adequately consider an inmate’s capacity for violence or that the jail’s system or that the jail’s practice of having staff perform hourly rounds checking cells is constitutionally inadequate.

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