WASHINGTON (CN) — A Maryland corrections officer won his Supreme Court appeal on Thursday, convincing the justices he should have another shot at fighting liability for an attack on an inmate.
“The question presented in this case is whether this preservation requirement extends to a purely legal issue resolved at summary judgment,” Justice Amy Coney Barrett wrote for the unanimous court.
Neil Dupree was a lieutenant working at a Maryland detention center in 2013 when a group of three guards entered the cell of an inmate, Kevin Younger, as he slept. Thrown from his bunk, Younger was bludgeoned with a mace can, radios and handcuffs, then left unconscious in a pool of his own blood. The attack left him bedridden for weeks, with injuries to his face, wrists, ribs, hands and legs.
All three guards who attacked Younger were convicted on criminal charges related to the beating, but Younger also brought a civil suit. In addition to his attackers, Younger wanted Dupree held liable, claiming the lieutenant ordered the attack as retaliation for an unrelated event.
A jury found all four men liable, awarding Younger $700,000 in damages. On appeal, Dupree argued Younger should not have been able to bring his suit before exhausting administrative remedies. Younger brought a grievance against Dupree that was dismissed after an internal investigation. The Fourth Circuit ruled against Dupree, however, finding that he forfeited this theory by failing to raise it prior to his appeal.
At the high court, Dupree urged the justices to reverse, claiming the district court’s summary judgment ruling preserved his arguments for appellate review. The court agreed.
“The Fourth Circuit was wrong to hold that purely legal issues resolved at summary judgment must be renewed in a post-trial motion,” Barrett wrote.
Barrett said Younger’s arguments would force the court to expand its precedents.
“Younger urges us to extend Ortiz’s holding to cover pure questions of law resolved in an order denying summary judgment,” Barrett wrote. “We decline the invitation.”
Appeals courts are bound in their jurisdiction by final decisions from district courts. In the summary judgment context, Barrett said, this applies to factual questions but not legal ones.
“Trials wholly supplant pretrial factual rulings, but they leave pretrial legal ruling undisturbed,” Barrett wrote. “The point of a trial, after all, is not to hash out the law.”
Amy Saharia, an attorney with Williams & Connolly representing Younger, and Andrew Tutt, an attorney with Arnold & Porter representing Dupree, did not immediately respond to requests for comment on the ruling.
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