Board of County Commissioners of Bryan County v. Brown
United States Supreme Court
520 U.S. 397 (1997)
- Written by Whitney Kamerzel , JD
Facts
While Jill Brown (plaintiff) was driving with her husband, the couple decided to avoid a police checkpoint. Bryan County Deputy Sheriff Robert Morrison and Reserve Deputy Stacy Burns chased down Brown’s car and ordered Brown out of the vehicle. Because Brown did not exit the car, Burns used an arm-bar technique to put Brown on the ground. Brown’s knees were severely injured. Brown sued Bryan County (the County) (defendant) under 42 U.S.C. § 1983 for Burns’s excessive force and attempted to attribute liability to the County based on Sheriff B. J. Moore’s decision to hire Burns, who was the his nephew. The sheriff admitted that he did not review Burns’s background, which contained several misdemeanors and driving infractions, although the sheriff did prohibit Burns from carrying a gun or operating a patrol car. The sheriff’s decision to hire Burns without reviewing Burns’s background differed from the sheriff’s usual practice. The federal district court held in Brown’s favor, and the court of appeals affirmed. The Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (O’Connor, J.)
Dissent (Breyer, J.)
Dissent (Souter, J.)
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