Reed v. Palmer

Dist. Ct. erred in granting defendant-prison official’s motion to dismiss on qualified immunity grounds plaintiffs’ section 1983 action, alleging that they, as Iowa delinquent youths, suffered from excessive use of isolation cells and excessive force committed by Wisconsin prison officials, and that defendant, as Iowa official contracting with Wisconsin officials to place plaintiffs in Wisconsin facility, knew or should have known about said isolation use and failed to either remove plaintiffs or adequately train or supervise employees of Wisconsin facility. Dist. Ct. acted prematurely in finding at pleading stage that defendant was entitled to qualified immunity, where: (1) allegations in complaint stated viable cause of action; (2) case law at time of plaintiffs’ custody indicated that isolation of pre-trial detainees was not reasonably related to legitimate governmental objective; and (3) it was impossible to determine at pleading stage whether instant constitutional violations occurred. Fact that plaintiffs were housed in Wisconsin facility did not require different result, where: (1) plaintiffs maintained that defendant was aware of reports indicating existence of excessive isolation occurring to plaintiffs at Wisconsin facility; and (2) juveniles in state custody have right not to be handed over to others whom state knows to be child abusers.