Due Process- Deliberate Indifference to Unjust Imprisonment

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7^th Circuit Court of Appeals

Case Name: John Sabo v. Megan Erickson

Case No.: 21-3332

Officials: Wood, St. Eve, and Jackson-Akiwumi, Circuit Judges.

Focus: Due Process- Deliberate Indifference to Unjust Imprisonment

Sabo’s probation term exceeded the maximum limit prescribed by Wisconsin law. Following his incarceration for violating the probation conditions beyond its designated period, Sabo filed a lawsuit under 42 U.S.C. § 1983 against two groups of defendants: Sheri Hicks and Debra Haley, officials from the Wisconsin Department of Corrections who failed to rectify his unlawful probation term, and Megan Erickson and Barb Hanson, the probation officers responsible for its enforcement. Sabo alleged that all four defendants violated his right to due process and demonstrated deliberate indifference to his unjust imprisonment.

Initially, the district court dismissed all claims against Hicks and Haley, as well as most claims against Erickson and Hanson. Subsequently, the court granted summary judgment in favor of Erickson and Hanson on the deliberate indifference and unreasonable seizure allegations. Sabo appealed the dismissal of his claims against Hicks and Haley.

The Seventh Circuit determined that Sabo’s complaint indeed articulated claims of deliberate indifference against Hicks and Haley. The court ruled that, given all facts and inferences in Sabo’s favor, the evidence did not conclusively establish qualified immunity for Hicks and Haley. Consequently, the court vacated the district court’s dismissal of those claims. However, it affirmed the district court’s rulings on all other aspects, including the summary judgment for Erickson and Hanson concerning the deliberate indifference and unreasonable seizure claims.

Vacated, remanded and affirmed

Decided 04/30/24

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