Hernandez v. Sheahan

Dist. Ct. erred in denying defendants-prison officials’ motion for summary judgment asserting qualified immunity in action alleging that defendants initiated investigation against plaintiff-prison guards and eventually reassigned them after major jailbreak occurred on their watch, where plaintiffs claimed that defendants took said action in retaliation for plaintiffs’ political support for rival Sheriff’s candidate. Defendants had probable cause to initiate instant investigation given confession by one correctional officer, who identified plaintiffs as having assisted him in allowing prisoners to escape or having advance knowledge of escape. Moreover, Dist. Ct. could not have found existence of material fact with respect to issue as to whether correctional officer’s confession was coerced where state court in criminal proceeding involving correctional officer had found that said confession was voluntary.