Criminal Justice on the Docket

Haynes v. Marshall
887 F.2d 700 (6th Cir. 1989)

Case Dates:
Thursday, 9 February, 1984 - Thursday, 12 October, 1989
Facts:

In 1984, Jimmy Haynes, an inmate at the Southern Ohio Correctional Facility (SOCF), was placed in the facility’s infirmary when he began “acting out.” With a history of psychiatric problems, he was required to take anti-psychotic medication, but had apparently not been given his medication that day. However, the guards were not authorized to administer the medication. When attempts to obtain authorization failed, Haynes was forcibly taken to a strip cell where he was shackled to the floor, beaten with clubs, and left to die.

Haynes’ mother Edna filed a complaint in district court against SOCF Superintendent Ronald C. Marshall and other prison personnel in both their individual and official capacities, alleging cruel and unusual punishment in violation of the Eighth Amendment, as well as wrongful death. ACLU of Ohio attorneys Elinor Alger, Bob Gensler and Richard Saphire served as Edna’s counsel. The defendants claimed that they were immune from prosecution on the grounds that government officials performing discretionary functions are generally protected from liability for civil damages, as long as their conduct does not violate statutory or constitutional rights. Throughout the pre-trial period, the ACLU’s attorneys successfully defeated several attempts by the defendants to dismiss. The court held that the defendants were immune in their official capacity, but not in their individual capacity. The court also found that supervisors could be held accountable for indifference to or unspoken agreement of their subordinates’ actions.

The ACLU of Ohio concluded its work on the case in 1990, as it was set to go to trial.