Hope v. Pelzer

Supreme Court of the United States · Torts

Tortsqualified immunity42 U.S.C. § 1983clearly established rightsmaterially similar factshitching postprisoner rightssummary judgment

Facts

The order states that, at the summary judgment stage, certain circumstances must be taken as true. Under those assumed facts, a prisoner was tied to a "hitching post." The case involves state officials sued in their individual capacities under 42 U.S.C. § 1983. The order does not provide further factual detail.

Issue

Whether state officials sued in their individual capacities under 42 U.S.C. § 1983 are entitled to qualified immunity unless they violated clearly established rights identified in a case with materially similar facts. Whether, on the facts that must be accepted as true at summary judgment, tying a prisoner to a hitching post violates clearly established constitutional rights for qualified-immunity purposes.

Rule

The order identifies the governing qualified-immunity inquiry as whether the officials violated constitutional or statutory rights that were clearly established. It specifically frames the question whether clearly established law requires a prior case with materially similar facts.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, Devin Shaw sued two state prison officers in their individual capacities under 42 U.S.C. § 1983 after they fastened him for hours to an outdoor restraint frame during a disciplinary incident. The officers moved for summary judgment, arguing they were entitled to qualified immunity because no prior reported decision involved that exact type of restraint frame.

Based only on the governing doctrine identified in the opinion text, which issue should a court address first in resolving the officers' qualified-immunity argument?

Explanation. The opinion text limits review to whether state officials sued individually under § 1983 are entitled to qualified immunity unless they violated rights clearly established by a case with materially similar facts. That makes the key issue whether materially similar precedent is required to show clearly established law. (Derived from Hope v. Pelzer (n.d.).)