Randall Williams v. Charleston County Sheriff's Office

• Court: Court of Appeals for the Fourth Circuit
• Decided: February 25, 2025
• Docket: 24-1238
• Status: Unpublished

Opinion

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UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-1238

RANDALL WILLIAMS, Personal Representative of the Estates of Shanice R. Dantzler-Williams and Miranda R. Dantzler-Williams; BETTY SIMMONS, Personal Representative of the Estate of Stephanie Dantzler,

Plaintiffs - Appellants,

v.

CHARLESTON COUNTY SHERIFF’S OFFICE,

Defendant - Appellee,

and

CHARLESTON COUNTY; EMILY PELLETIER; CLINTON SACKS,

Defendants.

Appeal from the United States District Court for the District of South Carolina at Charleston. David C. Norton, U.S. District Court Judge. (2:23-cv-02149-DCN)

Submitted: November 14, 2024 Decided: February 25, 2025

Before HARRIS, HEYTENS, and BERNER, Circuit Judges.

Affirmed by unpublished per curiam opinion. USCA4 Appeal: 24-1238 Doc: 43 Filed: 02/25/2025 Pg: 2 of 6

ON BRIEF: Richard A. Hricik, LAW OFFICES OF RICHARD A. HRICIK, PA, Mount Pleasant, South Carolina; Clifford Bush, III, THE LAW OFFICE OF CLIFFORD BUSH, III, LLC, Beaufort, South Carolina, for Appellants. Elloree A. Ganes, Evan M. Sobocinski, Deborah Harrison Sheffield, HOOD LAW FIRM, LLC, Charleston, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

This appeal arises from a heartbreaking accident. On Mother’s Day in 2022,

Stephanie Dantzler and her adult daughters, Shanice and Miranda Dantzler-Williams, were

driving in Charleston County, South Carolina. Nearby, two Charleston County sheriffs,

Deputies Emily Pelletier and Clinton Sacks, were responding to a non-emergency report

of a stalled vehicle. Without activating her car’s emergency lights or sirens, Pelletier sped

through a stop sign, crossed multiple lanes of traffic, and struck the women’s car. Dantzler

and her daughters suffered catastrophic injuries, and died shortly after.

The plaintiffs in this action are Randall Williams, representing the estate of his

daughters Shanice and Miranda, and Betty Simmons, representing the estate of her

daughter Dantzler. In their complaint, the plaintiffs brought multiple claims against

Deputies Pelletier and Sacks, in both their individual and official capacities; Charleston

County; and the Charleston County Sheriff’s Office. This appeal involves only some of

the plaintiffs’ claims against one of the defendants, the Charleston County Sheriff’s

Office.1

The County Sheriff’s Office filed a motion to dismiss the plaintiffs’ “Monell” claims

against it, in which the plaintiffs sought to hold the Sheriff’s Office liable under 42 U.S.C.

1 The plaintiffs’ many other claims will proceed before the district court, and we of course express no view as to their merits. We may review the district court’s ruling as to this subset of the plaintiffs’ claims because the district court certified its order as a final judgment under Rule 54(b) of the Federal Rules of Civil Procedure. See Williams v. Pelletier, No. 2:23-CV-02149-DCN, 2024 WL 1075444, at *1 (D.S.C. Mar. 12, 2024).

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§ 1983 as a municipality. See Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658

(1978). The Sheriff’s Office invoked the state’s Eleventh Amendment immunity from suit,

contending that is not a municipality but instead an “arm of the state” for purposes of the

Eleventh Amendment.

The district court agreed and dismissed the § 1983 claims against the Sheriff’s

Office. Williams v. Pelletier, No. 2:23-CV-02149-DCN, 2023 WL 8627812, at *5 (D.S.C.

Dec. 13, 2023). In Cromer v. Brown, 88 F.3d 1315 (4th Cir. 1996), as the district court

explained, the Fourth Circuit had already considered the Eleventh Amendment status of

South Carolina’s county sheriff’s offices, and determined that they are agents of the state

protected from suit by Eleventh Amendment immunity. See Williams, 2023 WL 8627812,

at *3. The court rejected the plaintiffs’ argument that an analysis under the factors laid out

in an earlier Fourth Circuit case pointed in a different direction, indicating that the Sheriff’s

Office should be treated as a municipality rather than a state entity. See id. at *5 (discussing

Ram Ditta ex rel. Ram Ditta v. Md. Nat’l Cap. Park & Plan. Comm’n, 822 F.2d 456 (4th

Cir. 1987)). Those factors, the court reasoned, were incorporated into the Fourth Circuit’s

subsequent decision in Cromer, and that decision remained “controlling precedent” that

foreclosed the plaintiffs’ position. Id.

We review the district court’s judgment de novo, see Hutto v. S.C. Ret. Sys., 773

F.3d 536, 542 (4th Cir. 2014), and we affirm for substantially the reasons given by the

district court.

The Eleventh Amendment immunizes “unconsenting State[s]” from suit in federal

court, and its protections extend to “agencies that may be properly characterized as ‘arm[s]

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of the State.’” Harter v. Vernon, 101 F.3d 334, 337 (4th Cir. 1996) (quoting Mt. Healthy

City Bd. of Educ. v. Doyle, 429 U.S. 274, 280 (1977)). To determine whether an entity like

the County Sheriff’s Office is an arm of the state entitled to Eleventh Amendment

immunity, this court employs a well-established four-factor balancing test. See Ram Ditta,

822 F.2d at 457–58. And in Cromer, we held, after considering the “factors relevant to the

immunity analysis,” that a South Carolina county sheriff is an “arm of the state” protected

from suit by the Eleventh Amendment. 88 F.3d at 1332. That is enough to resolve this

case.

On appeal, as before the district court, the plaintiffs argue that an independent

analysis of the Ram Ditta factors would show that the County Sheriff’s Office is not a state

agency for these purposes, and that Cromer should not be followed because it pays

insufficient attention to those factors. It is true that Cromer’s analysis is brief and does not

expressly address Ram Ditta, instead invoking generally the “relevant factors.” But

Cromer is directly on point, and its binding effect does not turn on the length or even the

persuasiveness of its reasoning. Cromer has not been abrogated by statute or superseded

by an en banc or Supreme Court decision, which means that we – like the district court –

are bound to follow it. See United States v. Ruhe, 191 F.3d 376, 388 (4th Cir. 1999) (setting

out general rule that a “simple panel” is bound by prior Fourth Circuit precedent “absent

contrary law from an en banc or Supreme Court decision”); Payne v. Taslimi, 998 F.3d

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648, 654 & n.2 (4th Cir. 2021) (describing duty to follow prior circuit precedent as

“mechanical mandate”).2

Accordingly, we affirm the judgment of the district court.

AFFIRMED

2 In support of their argument under the Ram Ditta factors, the plaintiffs have asked us to take judicial notice of certain publicly available facts about the fiscal workings of Charleston County and the State of South Carolina Insurance Reserve Fund, through which the County Sheriff’s Office is insured. Because we now hold that we are bound by Cromer and not at liberty to undertake a new and independent analysis, we deny that motion as moot. 6