Hoffman v. Knoebel

Federal 7th Circuit Court
Civil Court
Section 1983 Action
Citation
Case Number: 
No. 17-2750
Decision Date: 
July 3, 2018
Federal District: 
S.D. Ind., New Albany Div.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendants-Drug Treatment Court officials and court bailiff’s motion for summary judgment in section 1983 action alleging that defendants violated due process rights of plaintiffs-participants in drug court program as alternative for their drug-related convictions, where plaintiffs served jail sentences as sanctions for violating terms of drug programs, and where said sentences went beyond number of days set by court and were imposed without procedural protections required by Indiana law. Although record showed that plaintiffs’ constitutional rights were violated, plaintiffs failed to present evidence as to how instant defendants were personally responsible for failure to provide due process protections in first instance. Ct. rejected plaintiffs’ argument that defendants had failed to intervene while plaintiffs were in jail or had failed to bring about earlier end to said incarcerations and noted that plaintiffs established, at best, that defendants were merely negligent in failing to timely arrange for suitable placement of plaintiffs in treatment facilities following expiration of jail sentences. Moreover fact that certain defendants arrested plaintiffs although said defendants lacked state-law authority to do so did not constitute viable 4th Amendment violation, since said arrests were made after issuance of valid arrest warrants and each plaintiff was promptly taken to drug court.