Law School Case Brief
Turner v. Palmer - 84 F. Supp. 3d 880 (S.D. Iowa 2015)
Under the doctrine of qualified immunity, a court must dismiss a complaint against a government official in his individual capacity that fails to state a claim for violation of clearly established statutory or constitutional rights of which a reasonable person would have known. To prevail at the Fed. R. Civ. P. 12(b)(6) motion to dismiss stage of the proceedings, a defendant must show that he or she is entitled to qualified immunity on the face of the complaint.
Plaintiff Jessica Turner filed this action against defendants Charles Palmer, Richard Shults, Deborah Hanus, Ilona Avery, Dr. Joan Gerbo, Revae Gabriel, and Deb Wilkens under 42 U.S.C. § 1983 for alleged Fifth, Eighth, and Fourteenth Amendment violations arising from her confinement in isolation cells at the Iowa Juvenile Home. Turner was placed in a juvenile home facility from the age of 16 to almost 18 years old, and was diagnosed with several psychiatric disorders. Turner's cause of action arose from her placement in small, concrete isolation cells for more than half the time she was confined at the juvenile home, and the treatment and conditions she experienced while in isolation.
Were defendants entitled to dismissal of the complaint under Fed. R. Civ. P. 12(b)(6) based on qualified immunity?
Defendants unsuccessfully argued for dismissal of the complaint based on qualified immunity. Plaintiff based her constitutional claims on defendants' systemic and continuous use of isolation cells at the juvenile home. Whether placing plaintiff in isolation was reasonably related to a legitimate institutional interest, or was for the legitimate purpose of containing her violent behavior, required a factual inquiry that could not be accomplished at the present stage of the proceedings. Defendants' current legal arguments did not render implausible the allegations in the complaint. The Bell decision, cited by defendants in support of the motion to dismiss, was distinguishable. In regards to defendants' argument that the claims were time-barred, the district court would not make a determination at the present juncture on the application of the discovery rule or Iowa Code § 614.8. The complaint was sufficient to warrant a factual inquiry into the application of the continuing violations doctrine.
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