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George Daniel Reid Terence Eason Robert H. Griswold Jerry Minter v. Paul T. Kayye I.O. Wilkerson, Jr. David T. Flaherty, and Johnston County Johnston County Board of Commissioners Norman C. Denning Frank B. Holding Howard B. Benton John M. Booker James W. Cash Freddy Narron F.A. Beasley
Citations: 885 F.2d 129; 1989 U.S. App. LEXIS 9675Docket: 88-7289
Court: Court of Appeals for the Fourth Circuit; July 6, 1989; Federal Appellate Court
George Daniel Reid, Terence Eason, Robert H. Griswold, and Jerry Minter appeal the dismissal of their 42 U.S.C. Sec. 1983 claim against several North Carolina state officials, arguing that these officials were aware of and failed to address constitutional violations at the Johnston County jail. The district court ruled that the alleged misconduct of the officials did not cause the claimed constitutional violations, leading to the dismissal of the case. Reid, a former pretrial detainee, initially sought classwide injunctive and declaratory relief, alongside individual damages for substandard conditions at the jail. The appeal focuses solely on the dismissal of individual damage claims against state officials, including David T. Flaherty, Dr. Paul Kayye, and I.O. Wilkerson, Jr. The appellants contended that these officials had both the authority and responsibility to resolve the issues at the jail, which operates under the oversight of the North Carolina Department of Human Resources (DHR). However, the court determined that the DHR Secretary's obligations under North Carolina law, specifically N.C.Gen. Stat. Sec. 153A-221 and related statutes, conferred discretionary powers rather than a mandatory duty to act. It concluded that the usage of "may" in the statutes indicated that DHR officials are not required to remedy substandard conditions, and thus their inaction could not constitute causation necessary for a Sec. 1983 claim. Consequently, since the officials had no duty to act, the court affirmed the dismissal of the appellants' claims against them. Appellants claim that appellees can be held liable for jail conditions under supervisory liability, despite the inapplicability of respondeat superior in Sec. 1983 cases. While supervisory officials may be liable for constitutional violations by subordinates in certain situations, this liability arises from the indifference or tacit approval of misconduct, not from a direct supervisory role. North Carolina law does not place appellants in a supervisory capacity, as the General Assembly's policy is focused on assisting local governments rather than overseeing or controlling them. The law emphasizes guidance and improvement of local confinement facilities through services like inspection and consultation, indicating that appellants lack the authority to remedy poor conditions in local jails. This conclusion aligns with the outcome in Bush v. Viterna, where a similar claim was dismissed due to the lack of a legal duty for the Texas Commission on Jail Standards to enforce jail conditions. Consequently, the court affirms the district court's decision, stating that supervisory liability cannot apply without a corresponding obligation to address constitutional deficiencies.