Debra Smith v. Gallia County, Ohio Jail

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 11, 2022
Docket21-3620
StatusUnpublished

This text of Debra Smith v. Gallia County, Ohio Jail (Debra Smith v. Gallia County, Ohio Jail) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Debra Smith v. Gallia County, Ohio Jail, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0023n.06

No. 21-3620

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

) FILED DEBRA SMITH, Jan 11, 2022 ) Plaintiff-Appellee, ) DEBORAH S. HUNT, Clerk ) v. ) ) GALLIA COUNTY, OHIO JAIL, et al., ) ON APPEAL FROM THE ) UNITED STATES DISTRICT Defendants, ) COURT FOR THE SOUTHERN ) DISTRICT OF OHIO SHERIFF MATT CHAMPLIN; CHIEF DEPUTY ) TROY JOHNSON; GALLIA COUNTY, OHIO ) COMMISSIONERS, ) ) Defendants-Appellants. )

Before: GIBBONS, ROGERS, and NALBANDIAN, Circuit Judges.

ROGERS, Circuit Judge. Debra Smith was working as a corrections officer at the Gallia

County Jail when several inmates injured her during an escape. At the time of her injuries, Smith

was on duty with another female corrections officer. Smith sued the jail and several local officials

under 42 U.S.C. § 1983, alleging that her substantive due process rights were violated by the jail’s

failure to follow its policy of having both male and female guards on duty when inmates are both

male and female. The district court held that Smith stated a substantive due process claim under

the state-created-danger exception. This was error, however, because Smith has failed to allege

facts demonstrating the presence of a special relationship or that the state created a special danger

by placing two female corrections officers on duty at the same time. In addition, because Smith Case No. 21-5585, Smith v. Gallia Cnty., Ohio Jail, et al.

has not stated a claim that an underlying constitutional violation occurred, the county cannot be

liable under Monell v. Department of Social Services. See 436 U.S. 658 (1978). Finally, with

respect to Smith’s state-law claims, the defendants are entitled to statutory immunity.

Debra Smith began working as a correctional officer at Gallia County Jail in 2015. Matt

Champlin, the Sheriff of Gallia County, “was responsible for the training and supervision of all”

corrections officers and inmates in the jail. The Chief Deputy of Gallia County, Troy Johnson,

was also responsible for supervising jail operations. In 2017, the Gallia County Sherriff’s Office,

led by Champlin, established a policy that “[w]hen both males and females are housed in the jail

at least one male and one female staff member shall be on duty at all times.” Smith claimed that

the purpose of the policy was “to protect female corrections office[r]s against the potential threat

of violent male criminals” and to “protect the privacy of inmates” by ensuring that they could face

“same sex correction[s] officers in times of privacy.” In an alleged violation of the policy,

however, Smith was occasionally placed on duty with only another female corrections officer

while there were male inmates in the prison.

On or about September 29, 2019, Smith was on duty with only one other female corrections

officer despite the presence of male inmates. Smith and the other female corrections officer were

assaulted by four male inmates in connection with their escape from the jail. One of the inmates

held a knife to Smith’s neck, and Smith stated she “suffered serious physical and mental injuries”

as a result of the attack. Smith also asserted more generally that the defendants “have a history of

ignoring inhumane conditions at the jail and contributing to unhealthy and dangerous conditions

at the facility for inmates and staff.” For example, Smith alleged that the Ohio Bureau of Adult

Detention permitted the jail to house eleven inmates at a time, but on September 29 the jail

2 Case No. 21-5585, Smith v. Gallia Cnty., Ohio Jail, et al.

contained about forty inmates. Smith also asserted that “numerous escapes and attempt[ed]

escapes” had occurred at the jail.

Smith sued the Gallia County Sheriff’s Office, Gallia County Jail, Sheriff Matt Champlin,

and Chief Deputy Troy Johnson under 42 U.S.C. § 1983, alleging that the defendants violated her

rights under the Eighth and Fourteenth Amendments. Smith also claimed that the county was

liable under Monell v. Department of Social Services for failing to train or establishing a policy

that was a moving force behind the constitutional violation. See 436 U.S. 658 (1978). Smith

further alleged that the defendants were negligent. The defendants filed a motion to dismiss for

failure to state a claim, and Smith filed an amended complaint. In the amended complaint, Smith

dismissed the Gallia County Jail and added the Gallia County Commissioners and individual

county commissioners as defendants. Smith specified that she was asserting both equal protection

and substantive due process claims under the Fourteenth Amendment, reiterated her Monell claim,

and alleged that defendants were liable for negligence and negligence per se in violation of Ohio

law. Smith added state-law claims for negligent training or supervision, premises liability, and

battery. The defendants filed a second motion to dismiss for failure to state a claim. In response,

Smith dismissed the Gallia County Sheriff’s Office and the individual county commissioners as

defendants, leaving only the Gallia County Commissioners, Sheriff Matt Champlin, and Chief

Deputy Troy Johnson. To the extent the defendants are sued in their official capacities, the suit is

effectively against the county. See Pineda v. Hamilton County, 977 F.3d 483, 494 (6th Cir. 2020).

Additionally, Champlin and Johnson are named in their individual capacities. In short, then, the

remaining defendants are Champlin and Johnson in their individual capacities, plus the county.

The district court granted the motion to dismiss in part and denied it in part. The court held

that Smith did not state an Eighth Amendment claim because she was not “incarcerated for a crime

3 Case No. 21-5585, Smith v. Gallia Cnty., Ohio Jail, et al.

or involuntarily confined such that it can be said she is being ‘punished.’” Although Smith

“adequately pled purposeful or intentional gender-based discrimination,” she did not state an equal

protection claim under the Fourteenth Amendment because she did not “allege that she suffered

an adverse employment action.” However, the court held that Smith stated a Fourteenth

Amendment substantive due process claim under the state-created-danger exception. The court

also determined that Smith stated a Monell claim against Gallia County for a failure to train, or for

maintaining a policy or custom, that enabled the underlying substantive due process violation.

Turning to Smith’s state-law claims, the court held that Smith could not state a cause of action for

battery and also dismissed the negligence per se claim. The court declined to grant qualified

immunity to Champlin and Johnson on both the federal and state-law claims, concluding that the

immunity determination was premature at the motion to dismiss stage. Consequently, the only

remaining claims were the § 1983 substantive due process claims against Champlin and Johnson,

the Monell claim against Gallia County, and the state-law negligence claims against Gallia County,

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Debra Smith v. Gallia County, Ohio Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/debra-smith-v-gallia-county-ohio-jail-ca6-2022.