Show-Me State Times

The United States Court of Appeals for the Eighth Circuit has reversed a lower court ruling and granted qualified immunity to a Missouri Department of Corrections supervisor accused of violating an inmate’s constitutional rights. The decision was announced by Missouri Attorney General Andrew Bailey.

The case involved an inmate who was injured while working in a prison metal plant, operating a press-brake machine. The plaintiff claimed that his supervisor failed to enforce the use of hand restraints intended to improve safety, which allegedly constituted a violation of the Eighth Amendment’s prohibition on cruel and unusual punishment. A district court had previously denied the supervisor’s motion for summary judgment based on qualified immunity, leading to an appeal.

In its published opinion, the Eighth Circuit found that the supervisor’s conduct did not meet the standard of “deliberate indifference” required for an Eighth Amendment violation. The court also determined that statements made by the supervisor regarding plant safety rules did not amount to criminal recklessness. Additionally, it held that previous cases such as Ambrose v. Young did not clearly establish that similar actions would violate federal law, and noted that workplace injuries in correctional settings have not been considered cruel and unusual punishment under analogous precedent in the circuit.

Missouri Attorney General Andrew Bailey commented on the outcome: “This ruling is a significant win for the rule of law and for all public servants who carry out their duties in good faith.”

The decision reinforces existing legal protections for public officials, clarifying that negligence alone does not constitute a constitutional violation under current interpretations of the Eighth Amendment.

“This case reaffirms a critical principle: that constitutional liability cannot be imposed on state officials based on hindsight or speculative risk,” said Bailey.

The full text of the Eighth Circuit Court decisions can be accessed online.