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Robert Beard v. A.L. Lockhart Sgt. Robinson Major Reed Employees, Arkansas Department of Correction
Citations: 716 F.2d 544; 1983 U.S. App. LEXIS 16964Docket: 83-1086
Court: Court of Appeals for the Eighth Circuit; September 13, 1983; Federal Appellate Court
Robert Beard, an inmate at the Arkansas Department of Corrections, filed a lawsuit under 42 U.S.C. § 1983 against several officials, including A.L. Lockhart, Sgt. Vernon Robinson, and Major Dale Reed. Beard alleged that Robinson threatened him and allowed another inmate to attack him while they were unsupervised, and claimed that Reed denied him medical care. Beard's suit against Lockhart was dismissed before trial. During the trial, Beard presented his testimony without additional witnesses. After his testimony, the district court granted the defendants' motion for involuntary dismissal under Fed. R. Civ. P. 41(b). Beard appealed, arguing that the court erred in dismissing Lockhart and in granting the dismissal motion. The court upheld the dismissal, stating that Beard’s testimony did not establish any misconduct by the prison officials; it only indicated that a fight occurred without Robinson's presence. Beard did not mention needing medical assistance. The court found no evidence supporting Beard's claims, leading to the dismissal of the case. Additionally, Beard's claim against Lockhart was based on vicarious liability, which is not applicable under § 1983. The court noted that, without findings of liability against any defendant, Lockhart could not be held liable even under a direct responsibility theory. Thus, the district court's judgment was affirmed.