Vasile v. City of Hartford
Qualified immunity protects government employees from legal responsibility in a civil-rights suit under 42 United States Code §1983, unless their conduct violates a clearly established right, pursuant to Harlow v. Fitzgerald, a 1982 U.S. Supreme Court decision. On March 22, 2007, Hartford police allegedly conducted a raid at a nightclub owned by the plaintiff, Richard Vasile, and arrested 114 people. The police used police vans to transport arrestees to police headquarters and held the arrestees in the vans, as they awaited processing. Allegedly, the plaintiff was in the last van, which left the nightclub at 4 a.m., and he was held in the van until 8 a.m., then processed and confined in an extremely crowded cell. Allegedly, he was unable to sit or to lie down, because there was no space, until he was released at approximately 1:30 p.m. Vasile sued the City of Hartford and five individual police officers, alleging that his 14th Amendment due-process rights were violated. Individual police officers moved for summary judgment and argued that they were entitled to qualified immunity. Qualified immunity protects government employees from legal responsibility in a civil-rights suit under 42 United States Code §1983, unless their conduct violates a clearly established right. Although confinement before trial cannot be punitive, without violating due-process rights, the District Court did not find caselaw on point that clearly indicated that the conditions of the plaintiff's short-term, pre-trial detention violated the Due Process Clause. As a result, the court could not conclude that the police officers violated a clearly established right. "[G]iven the exigencies the officers faced as a result of the arrests of 114 people," wrote the court, "a reasonable person in their position could believe that detaining the arrestees in overcrowded conditions was unavoidable and thus not unlawful." The court granted the police officers' motion for summary judgment. The court also found that the plaintiff failed to produce evidence of a municipal policy or custom to keep pre-trial detainees in inhumane conditions, and it granted the city's motion for summary judgment on the plaintiff's Monell claim.