Larry Williams v. Jimmy Carter, Sheriff, Poinsett County Gene Henderson, Head Jailor, Poinsett County Glen Miller, Trustee, Poinsett County Cleo Shelly, Trustee, Poinsett County
Docket: 95-2945
Court: Court of Appeals for the Eighth Circuit; February 5, 1996; Federal Appellate Court
Larry Williams, a former pretrial detainee at the Poinsett County Jail, appealed the dismissal of his 42 U.S.C. § 1983 claims regarding unconstitutional jail conditions. The Eighth Circuit previously reversed an initial dismissal due to the District Court's insufficient consideration of Williams's witness requests. Upon remand, the District Court appointed counsel for Williams, who submitted a narrowed list of witnesses but did not request subpoenas for them. The magistrate judge heard testimony from a commissioner who confirmed prior evidence and recommended denial of Williams's claims. The District Court adopted this recommendation, dismissing the case and allowing counsel to withdraw. Williams later filed untimely pro se objections, arguing that the mandate for calling witnesses was mishandled and that key testimonies were denied. The District Court reviewed these objections but upheld the magistrate judge's recommendations. The Eighth Circuit reviewed the case de novo for legal conclusions and for clear error on factual findings, ultimately affirming the District Court's decision. The court noted that the decision to call witnesses is a matter of counsel's judgment, and since counsel did not request any subpoenas, the District Court did not err in its ruling. The appeal was thus denied, affirming the lower court's dismissal of Williams's claims.