Fourteenth Amendment’s Due Process Clause-Jury Instructions

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7^th Circuit Court of Appeals

Case Name: Minosa Echols v. Teresa Johnson

Case No.: 22-3230

Officials: Ripple, Scudder, and Jackson-Akiwumi, Circuit Judges.

Focus: Fourteenth Amendment’s Due Process Clause-Jury Instructions

Echols, a civil detainee in an Illinois facility, sustained serious injuries in an attack by another resident. Echols sued under 42 U.S.C. § 1983, alleging that three security officers, present during the assault, violated his rights under the Fourteenth Amendment’s Due Process Clause by failing to protect him. The case proceeded to trial, resulting in a jury verdict in favor of the defendants. Echols appealed, arguing that the district court made a legal error in its jury instruction.

The district court had instructed the jury that for Echols to succeed on his failure-to-protect claim, he needed to demonstrate that the officer in question subjectively knew that the other resident posed a risk of harm to him. On appeal, the Seventh Circuit agreed that this jury instruction was incorrect. The court clarified that Echols did not need to prove subjective awareness of the risk of harm. Instead, the jury should have been instructed to assess whether a reasonable officer in the defendant’s position would have recognized that the conditions in the dayroom created a risk of harm to Echols, and whether the defendant acted unreasonably in responding to that risk.

However, for Echols to succeed on appeal, he also needed to demonstrate that this error affected the outcome of the case. The court determined that Echols failed to show prejudice. It concluded that the attack was so unforeseeable that no reasonable officer, facing the circumstances at hand, could have anticipated the sudden assault or taken different actions to safeguard Echols.

Affirmed.

Decided 06/27/24

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