Attorney General Bailey Secures Major Eighth Circuit Victory Affirming Qualified Immunity For Missouri Corrections Official

JEFFERSON CITY, Mo. – Today, Missouri Attorney General Andrew Bailey announced that the United States Court of Appeals for the Eighth Circuit has issued a decisive opinion reversing a lower court ruling and granting qualified immunity to a Missouri Department of Corrections supervisor accused of constitutional violations. This outcome reinforces long-standing legal protections for public officials and affirms that negligence alone does not constitute a constitutional violation under the Eighth Amendment.

This ruling is a significant win for the rule of law and for all public servants who carry out their duties in good faith. The case arose after an inmate working in a prison metal plant suffered an injury while operating a press-brake machine. The plaintiff alleged that his supervisor violated the Eighth Amendment by failing to enforce the use of hand restraints designed to enhance safety. The district court denied the supervisor’s motion for summary judgment on the basis of qualified immunity, prompting an interlocutory appeal.

In a published opinion, the Eighth Circuit reversed and remanded the lower court’s decision, finding that:

• The conduct in question, even if negligent, did not rise to the level of “deliberate indifference” required to establish a constitutional violation;
• The supervisor’s alleged statements about plant safety rules did not demonstrate criminal recklessness;
• Prior case law, including Ambrose v. Young, did not clearly establish that the actions in this case violated federal law; and
• Analogous precedent in the Eighth Circuit has consistently held that workplace injuries in correctional settings, do not meet the constitutional threshold for cruel and unusual punishment.

This case reaffirms a critical principle: that constitutional liability cannot be imposed on state officials based on hindsight or speculative risk.

The full Eighth Circuit Court decisions can be read here.