Joseph L. Spencer v. Knapheide Truck Equipment Co. The Board of Police Commissioners of the Kansas City, Missouri Police Department, Through It Members: Dr. Stacy Daniels, in Her Official Capacity as Vice President, Board of Police Commissioners Jeffrey J. Simon, in His Official Capacity as Treasurer, Board of Police Commissioners Joseph J. Mulvihill, in His Official Capacity as a Member, Board of Police Commissioners Emmanuel Cleaver, in His Official Capacity as Ex Officio Member, Board of Police Commissioners and Mayor, City of Kansas City, Missouri Knapheide Manufacturing Company, Knapheide Truck Equipment Co., Knapheide Manufacturing Company, Third-Party
Docket: 98-3717
Court: Court of Appeals for the Third Circuit; September 13, 1999; Federal Appellate Court
Joseph L. Spencer appeals the district court's summary judgment against him in his section 1983 lawsuit regarding injuries sustained during his arrest and transport in a patrol wagon. On January 30, 1992, Officer Trussler, responding to a call, arrested the intoxicated Spencer for simple assault and transported him in a patrol wagon without any safety restraints. During the ride, Spencer claims he was thrown against the compartment's bulkhead, resulting in severe injuries and quadriplegia.
Spencer’s complaint included multiple claims against members of the Kansas City Board of Police Commissioners and Knapheide Truck Equipment Company, which manufactured the patrol wagon. Claims against Knapheide were either settled or dismissed. The Board moved for summary judgment, arguing against allegations that included maintaining unsafe transport policies and failing to protect intoxicated detainees, which Spencer argued violated his Fifth and Fourteenth Amendment rights. The district court ruled in favor of the Board, affirming the summary judgment.
Summary of the legal excerpt:
The review of a grant of summary judgment is conducted de novo, determining if there is no genuine issue of material fact and if the moving party is entitled to judgment as a matter of law. Spencer's section 1983 suit against Board members in their official capacities is treated as a suit against the municipality. To establish municipal liability, a plaintiff must prove a violation of constitutional rights due to official policy or pervasive misconduct among non-policymaking employees. The district court found that Spencer did not demonstrate a pattern of constitutional violations or that the Board was deliberately indifferent to the safety of individuals transported in patrol wagons. This 'deliberate indifference' standard is central to Spencer's appeal, where he argues the court erred by applying the subjective standard associated with the Eighth Amendment instead of an objective standard. The Constitution requires the State to ensure the safety and well-being of individuals in custody. While Spencer acknowledges the applicability of a deliberate indifference standard, he asserts that the court should have used an objective interpretation, which holds municipalities liable when an obvious inadequacy is likely to result in constitutional violations.
The standard for assessing due process violations for pretrial detainees remains ambiguous. The Supreme Court has stated that pretrial detainees are entitled to at least the same protection under the Fourteenth Amendment as convicted prisoners under the Eighth Amendment. However, the applicable standard has not been definitively established in the circuit. Although there have been suggestions for a stricter standard than deliberate indifference in cases of inadequate medical care for pretrial detainees, no specific standard has been defined.
Despite the unclear standard, even if an objective deliberate indifference standard were applied, the claims by Spencer would still not demonstrate a due process violation. The deliberate indifference standard requires that the alleged deprivation be 'sufficiently serious' and pose a 'substantial risk of serious harm.' The court found that the Board's policies regarding the transportation of detainees in patrol wagons, even without safety restraints, did not present an obvious substantial risk of serious harm, particularly given existing police guidelines aimed at ensuring caution during transport.
Spencer argued that prior citizen complaints indicated the Board's deliberate indifference, but these complaints mostly referenced minor injuries or instances of being tossed about without serious consequences. Thus, they did not establish a substantial risk of serious harm.
Additionally, Spencer's claim that the Board's policies constituted punishment was rejected. The absence of an expressed intent to punish, along with the Board's legitimate concern for safety in transporting individuals, indicates that the policy was related to a legitimate penological goal. The decision not to install safety devices was also viewed in light of the guidelines and the lack of serious injury complaints.
Ultimately, while the court expressed sympathy for Spencer's situation, it concluded that the circumstances did not amount to a constitutional deprivation, affirming the district court's decision.
The Honorable Richard G. Kopf, a District Court Judge for Nebraska, is sitting by designation. Officer Trussler asserts that he instructed Spencer to sit on the floor of the police wagon twice, but Spencer denies ever receiving such instructions. Spencer characterizes his status during the incident as that of an arrestee rather than a pretrial detainee; however, both his complaint and the district court's order treat the matter in terms of pretrial detainee rights, a classification that does not affect the analysis of his claim. Relevant procedural instructions from the Kansas City, Missouri Police Department state that officers must advise prisoners to exercise caution when entering the wagon, to sit either at the front or on the floor, and to place any prisoner who cannot protect themselves from potential injury on the floor. Additionally, officers are required to drive in a manner that ensures the safety of the prisoners.
