Bennie Mae Snead v. Georgia Department of Corrections

CourtCourt of Appeals for the Eleventh Circuit
DecidedSeptember 10, 2024
Docket24-10511
StatusUnpublished

This text of Bennie Mae Snead v. Georgia Department of Corrections (Bennie Mae Snead v. Georgia Department of Corrections) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennie Mae Snead v. Georgia Department of Corrections, (11th Cir. 2024).

Opinion

USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 1 of 10

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 24-10511 Non-Argument Calendar ____________________

BENNIE MAE SNEAD, deceased CURTIS MINCEY, Plaintiff-Appellee, versus GEORGIA DEPARTMENT OF CORRECTIONS, WARDEN DESHAWN JONES,

Defendants-Appellants,

DOE JOHN AND JANE , Correctional Officers 1-10, individually and in their official capacities as USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 2 of 10

2 Opinion of the Court 24-10511

correctional officers,

Defendants.

Appeal from the United States District Court for the Middle District of Georgia D.C. Docket No. 4:23-cv-00153-CDL ____________________

Before WILSON, BRANCH, and LUCK, Circuit Judges. PER CURIAM: The Georgia Department of Corrections (“GDOC”) and former Rutledge State Prison Warden Deshawn Jones appeal the district court’s order denying their motion for judgment on the pleadings based on qualified and sovereign immunity under Georgia law. They argue that the district court erred in allowing the case to proceed to discovery and deferring a decision on their immunity defenses. After review, we agree that the district court erred. Accordingly, we vacate the decision and remand the case for the district court to address the immunity defenses in the first instance. I. Background Bennie Mae Snead’s brother, Curtis Mincey, was an inmate at Rutledge State Prison in Georgia when he died in July 2021. USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 3 of 10

24-10511 Opinion of the Court 3

Following his death, Snead filed a wrongful death complaint in Georgia Superior Court against the GDOC, Deshawn Jones who was the warden of Rutledge, and unnamed corrections officers John and Jane Does #1-10. According to the complaint, in “early July” 2021, an anonymous inmate contacted Snead and told her that he had not seen Mincey for several days. In response, Snead made several attempts to reach her brother by calling the prison and speaking with a corrections officer and her brother’s counselor. Snead expressed concerns for her brother’s safety and welfare, but her requests to speak to her brother were denied and no one checked on his welfare. Subsequently, on July 22, 2021, she received a phone call that Mincey had died. The caller told her that Warden Jones would be in contact with more information. However, according to Snead, Warden Jones “has failed or refused to speak” with her concerning her brother’s death. An autopsy by the Georgia Bureau of Investigation determined that Mincey’s death was the result of a homicide with “Blunt Force Trauma of the Head, Neck[,] Torso and Extremities.” In the complaint, Snead maintained that her brother “was suffering from schizophrenia and or some other form of mental illness” and “requested medical and psychological assistance,” but that unnamed correctional officers and staff refused to provide assistance and instead “intimidated [Mincey], used unnecessary force, brutalized and battered him, resulting in catastrophic injury USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 4 of 10

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and death.” Snead also alleged that she sent ante litem notice to the defendants but that the defendants refused to respond. Based on the above allegations, Snead asserted claims for violations of Mincey’s civil rights under 42 U.S.C. § 1983, including claims for excessive force, cruel and unusual punishment, deliberate indifference to a serious risk of harm, deliberate indifference to Mincey’s medial needs; municipal liability; “Canton Liability”; violations of the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act; and myriad claims under Georgia state law. Snead sought compensatory, special, and punitive damages, as well as attorney’s fees. GDOC and Warden Jones removed the case to federal court based on federal question jurisdiction and moved for judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(c). They asserted that Snead’s complaint “[was] nothing more than an alleged wrong in search of a claim and a defendant,” and that her claims were barred by the Eleventh Amendment, qualified immunity, as well as sovereign immunity under Georgia law, and otherwise failed to state a viable claim for relief under federal or state law. In response, Snead argued that because her brother’s death was the result of “foul play,” his constitutional rights were necessarily violated, such that “at the very least, [she] should be provided the opportunity to conduct discovery.” She asserted that she had pleaded her case as best as she could given that she “was not present [when her brother was killed]; her brother [was] dead USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 5 of 10

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and [could not] tell her what happened; and the Defendants have no incentive to reveal what actually happened.” Upon review, the district court granted the motion in part and denied it in part. The district court granted the motion in part as to the § 1983 claims against GDOC and the Warden in his official capacity, and the individual capacity claims against the Warden under the ADA and the Rehabilitation Act. Thus, all that remained were the individual capacity claim against the Warden under § 1983, the claims against GDOC under the ADA and the Rehabilitation Act, and the state law claims. With regard to those remaining claims, the district court acknowledged that Snead “did not allege with specificity the circumstances surrounding her brother’s beating or how he was discriminated against because of a disability.” Furthermore, the district court noted that all of Snead’s allegations were “purely conclusory because [Snead] [could not], without some discovery, identify any officers who participated in Mincey’s beating, disregarded a substantial risk of harm to Mincey, or intentionally discriminated against Mincey because of a disability.” Yet, despite the conclusory nature of the complaint, the district court denied the defendants’ motion for judgment on the pleadings, explaining that Snead could not “make specific allegations unless she had an opportunity to learn what happened.” Accordingly, the court deferred ruling on the immunity defenses, and instructed the defendants to renew those USCA11 Case: 24-10511 Document: 23-1 Date Filed: 09/10/2024 Page: 6 of 10

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defenses after discovery at the summary judgment stage. The defendants appealed. II. Discussion The defendants argue that the district court erred in deferring ruling on their qualified immunity and sovereign immunity arguments and instead allowing the case to proceed to discovery notwithstanding the conclusory nature of the complaint. Snead in turn argues that we lack jurisdiction because the district court merely deferred ruling on the immunity motions, which is not a final decision subject to appeal and, alternatively, that the district court did not err in deferring ruling on the immunity defenses because Snead cannot properly plead her claims unless she has an opportunity to conduct discovery. We first address the jurisdictional argument and, because we conclude that we have jurisdiction, we then turn to the defendants’ argument on appeal. A. Jurisdiction Snead maintains that we lack jurisdiction over this appeal because the district court merely deferred ruling on the immunity defenses, and, therefore, the judgment in question is not a final decision.

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Bluebook (online)
Bennie Mae Snead v. Georgia Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennie-mae-snead-v-georgia-department-of-corrections-ca11-2024.