McLin v. Trimble

1990 OK 74, 795 P.2d 1035, 61 O.B.A.J. 1633, 1990 Okla. LEXIS 64, 1990 WL 82227
CourtSupreme Court of Oklahoma
DecidedJune 19, 1990
Docket73237
StatusPublished
Cited by64 cases

This text of 1990 OK 74 (McLin v. Trimble) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McLin v. Trimble, 1990 OK 74, 795 P.2d 1035, 61 O.B.A.J. 1633, 1990 Okla. LEXIS 64, 1990 WL 82227 (Okla. 1990).

Opinions

SUMMERS, Justice.

I.

The first question is whether two Corrections Department employees named as defendants in an inmate’s civil rights ease may have rejection of their “qualified immunity” defense reviewed in this court pri- or to trial. The second is whether that defense insulates them from having to defend a suit for damages. We answer both questions in the affirmative.

The plaintiff, J.C. Stewart, brought a civil rights action against three employees of the Oklahoma Department of Corrections. The defendants filed a motion for summary judgment based on the defense of qualified immunity. The trial court denied the motion and two of the defendants appealed. Their petition in error requested an immediate appeal or alternatively, review of the trial court’s action by extraordinary relief. They then filed an amended application for extraordinary relief (prohibition) and again asserted a right to an immediate appeal.

The petitioners correctly state that they have a right to an immediate appeal when a federal court rejects a defense of qualified immunity. They assert that this court should also grant immediate appeals from interlocutory orders which deny a claim of qualified immunity in an action under 42 U.S.C. § 1983. They argue that qualified immunity is not merely an immunity from damages, but immunity from suit and trial as well. Thus, they conclude that a post-trial appeal is inadequate to protect their immunity. The respondent/real party in interest has not responded.1

We assume original jurisdiction pursuant to Art. VII, § 4, of the Oklahoma Constitution in order to address the issue of first impression concerning interlocutory review in civil rights actions brought in state courts. See, First National City Bank of New York v. Smith, 531 P.2d 321 (Okla.1975).

II.

The question before us involves the scope of qualified immunity in § 1983 actions brought in state courts. The qualified immunity doctrine may be stated thus:

“government officials performing discretionary functions generally are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” Mitchell v. Forsyth, 472 U.S. 511, 517, 105 S.Ct. 2806, 86 L.Ed.2d 411 (1985), quoting Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727 [2738] 73 L.Ed.2d 396 (1982).

Qualified immunity was provided by common law and was not abolished by the enactment of § 1983. Pierson v. Ray, 386 U.S. 547, 554-555, 87 S.Ct. 1213, 1217-1218, 18 L.Ed.2d 288 (1967).

Although § 1983 provides a “uniquely federal remedy”, Mitchum v. Foster, 407 U.S. 225, 239, 92 S.Ct. 2151, 2160, 32 L.Ed.2d 705 (1972), and, thus, a federal cause of action, United States v. Memphis Cotton Oil Co., 288 U.S. 62, 68, [1037]*103753 S.Ct. 278, 280-81, 77 L.Ed. 619 (1933), the courts of this state hear § 1983 claims. Willbourn v. City of Tulsa, 721 P.2d 803 (Okla.1986).

However, the assertion of an immunity is not a state-law created defense to a federal cause of action. The issue of the application of an immunity is one of federal law. Martinez v. California, 444 U.S. 277, 284 n. 8, 100 S.Ct. 553, 558 n. 8, 62 L.Ed.2d 481 (1980) (state sovereign immunity not applicable to § 1983 action in state court). See also, Steinglass, The Emerging State Court § 1983 Action: A Procedural Review, 38 U.Miami L.Rev. 381, 475 (1984). The Court emphasized this point in Felder v. Casey, 487 U.S. 131, 108 S.Ct. 2302, 101 L.Ed.2d 123 (1988), wherein it explained that state immunity law was “preempted” in § 1983 actions brought in state court because state immunity law would thwart the Congressional remedy and that immunities to § 1983 actions were provided by its prior decisions. Id. 108 S.Ct. at 2307. Thus, the scope of qualified immunity in a state court proceeding is the same as that found in a federal court.

III.

There can be no doubt that a defendant is entitled to an immediate appeal from an interlocutory adjudication of qualified immunity in federal court. In Mitchell v. Forsyth, 472 U.S. 511, 105 S.Ct. 2806, 86 L.Ed.2d 411 (1985), a plurality of the Supreme Court2 discussed the earlier Harlow v. Fitzgerald, 457 U.S. 800, 102 S.Ct. 2727, 73 L.Ed.2d 396 (1982), and said:

[1038]*1038“Harlow thus recognized an entitlement not to stand trial or face the other burdens of litigation, conditioned on the resolution of the essentially legal question whether the conduct of which the plaintiff complains violated clearly established law. The entitlement is an immunity from suit rather than a mere defense to liability; and like an absolute immunity, it is effectively lost if a case is erroneously permitted to go to trial. Accordingly, the reasoning that underlies the immediate appealability of an order denying absolute immunity indicates to us that the denial of qualified immunity should be similarly appealable; in each case, the district court’s decision is effectively unreviewable on appeal from a final judgment.” Mitchell v. Forsyth, 472 U.S. at 526-527, 105 S.Ct. at 2815-2816. (Emphasis in original).

The opinion in Mitchell recognized that qualified immunity is an entitlement to not be subject to suit, and that entitlement is effectively lost if the suit erroneously goes to trial. Thus, a review of an erroneous pretrial decision regarding qualified immunity was held available by an appeal.

Federal law is paramount to any state law which conflicts with federal law in § 1983 actions brought in state court. Felder v. Casey, 487 U.S. 131, 108 S.Ct. 2302, 2306, 101 L.Ed.2d 123 (1988). See also, Wolcher, Sovereign Immunity and the Supremacy Clause: Damages Against the States in Their Own Courts for Constitutional Violations, 69 Calif.L.Rev. 189, 239 (1981). In Felder, the court said with regard to a state notice-of-claim statute:

“Because the notice-of-claim statute at issue here conflicts both in its purpose and effects with the remedial objectives of § 1983, and because its enforcement in such actions will frequently and predictably produce different outcomes in § 1983 litigation based solely on whether the claim is asserted in state or federal court, we conclude that the state law is pre-empted when the § 1983 action is brought in state court.” Id. 108 S.Ct. at 2306-2307.

The court thus found a state statute to be preempted because a § 1983 action would have a predictably different outcome merely because the action was brought in state court instead of federal court. The Court emphasized this view when it said that: “States may not apply such an outcome-determinative law when entertaining substantive federal rights in their courts.” Id. 108 S.Ct. at 2308. The Court also said:

“Just as federal courts are constitutionally obligated to apply state law to state claims, see Erie [R. Co. v. Tompkins], supra, 304 U.S. [64], at 78-79, 58 S.Ct. [817], at 822-823 [82 L.Ed.

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Cite This Page — Counsel Stack

Bluebook (online)
1990 OK 74, 795 P.2d 1035, 61 O.B.A.J. 1633, 1990 Okla. LEXIS 64, 1990 WL 82227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mclin-v-trimble-okla-1990.