You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Sherrie Kiesling v. John D. Troughton, Third Judicial District Judge for Lincoln County Robert M. McCloud Third Judicial District Clerk of Lincoln County Lynn W. Clark, Lincoln County Sheriff Tim Malik, Lincoln County Deputy Sheriff Kathleen Davison Clyde Gephart Robert Murdock, Lincoln County Commissioners

Citations: 107 F.3d 880; 1997 WL 111256; 1997 U.S. App. LEXIS 7942Docket: 95-8048

Court: Court of Appeals for the Third Circuit; March 12, 1997; Federal Appellate Court

Narrative Opinion Summary

In the case of Sherrie Kiesling v. John D. Troughton et al., the Tenth Circuit Court of Appeals addressed a child custody dispute that evolved into federal litigation following judicial orders for law enforcement to take custody of Kiesling's children, leading to her arrest due to noncompliance. Kiesling, representing herself, alleged constitutional violations against various parties, including a judge and law enforcement officers. The defendants obtained summary judgment, which was affirmed on appeal, as no genuine issues of material fact were found. The court upheld judicial and quasi-judicial immunity for actions within jurisdiction and under 42 U.S.C. § 1983. Kiesling's claims of false arrest and excessive force against a deputy were dismissed due to probable cause and reasonable force assessments. Additionally, lack of evidence led to the dismissal of training and supervision claims against the sheriff and county commissioners. Kiesling's additional claims were declared meritless, and her nolo contendere pleas to criminal charges were confirmed. The court's rulings reflect adherence to procedural and substantive legal standards, affirming the district court's decisions.

Legal Issues Addressed

Citation of Unpublished Opinions

Application: The court allowed citation of unpublished opinions for their persuasive value on a material issue, provided proper copies were attached or presented during oral arguments.

Reasoning: Citation of unpublished opinions is allowed if they provide persuasive value on a material issue and proper copies are attached or provided during oral arguments.

Claims of Failure in Training and Supervision

Application: Claims against Sheriff Clark were dismissed due to lack of evidence of improper training or supervision.

Reasoning: Kiesling's claims against Sheriff Clark are based on alleged failures in training and supervision. However, no evidence of improper training was found, leading to a dismissal of claims against him as well.

Excessive Force and Fourth Amendment

Application: The court determined that Deputy Malik's use of force was reasonable given Kiesling's resistance, and thus did not violate the Fourth Amendment.

Reasoning: Regarding the excessive force claim, the standard is whether Malik's actions were objectively reasonable, assessed from the perspective of a reasonable officer on the scene.

Judicial Immunity

Application: The court affirmed that judges have absolute immunity for judicial acts performed within their jurisdiction, which was applicable to Judge Troughton in this case.

Reasoning: The court noted that judges possess absolute immunity for judicial acts performed within their jurisdiction, which applied to Judge Troughton in this case.

Municipal Liability under Supervisory Standards

Application: The Lincoln County Commissioners' summary judgment was affirmed due to lack of evidence of constitutional deprivation or liability under supervisory standards.

Reasoning: The Lincoln County Commissioners were also named as defendants, but without evidence of a constitutional deprivation or their liability under supervisory standards, their summary judgment was affirmed.

Probable Cause for Arrest

Application: The court found probable cause for Deputy Malik's arrest of Kiesling due to her refusal to comply with police orders and assault of a partner.

Reasoning: False arrest requires a lack of probable cause, which is established here since Malik arrested her after she refused police orders and assaulted a partner.

Quasi-Judicial Immunity under 42 U.S.C. § 1983

Application: The clerk's actions were considered immune under 42 U.S.C. § 1983 when performing quasi-judicial duties.

Reasoning: Similarly, the clerk's actions were deemed immune under 42 U.S.C. § 1983 when performing quasi-judicial duties.

Summary Judgment Standards

Application: Summary judgment was deemed appropriate as there were no genuine issues of material fact and the defendants were entitled to judgment as a matter of law.

Reasoning: The appellate court affirmed this judgment, stating that summary judgment is appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.