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Seana Barnettv.Sara Macarthur, Et Al

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.18-12238
DecidedApril 15, 2020
Reporter436 U.S. 658
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsConstitutional LawFourth AmendmentSection 1983Municipal LiabilitySummary JudgmentReversalRemand
Case Summary

Seana Barnett was arrested on suspicion of driving under the influence, but two breath tests showed no alcohol and there was no evidence of impairment by another substance. She remained detained for eight hours under a sheriff’s mandatory DUI-hold policy, including after posting bond. Barnett sued under Section 1983, alleging an unlawful arrest and detention. After a jury found for the arresting deputy, the Eleventh Circuit held that the verdict did not resolve whether the Sheriff’s continuing detention policy violated the Fourth Amendment. The jury had been asked whether the deputy intentionally caused a constitutional violation, not whether the policy itself caused an unlawful detention. The court therefore reversed summary judgment for the Sheriff on Barnett’s municipal-liability claim and remanded for trial on that claim. It affirmed the judgment in all other respects.

Opinion

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