Reams v. Irvin
United States Court of Appeals for the Eleventh Circuit
561 F.3d 1258 (2009)
- Written by Sean Carroll, JD
Facts
Laura Fokes (defendant), an equine inspector for the Georgia Department of Agriculture (GDA), impounded 49 horses and donkeys belonging to Edna Reams (plaintiff) on the grounds that they were not provided sufficient food and water. Prior to the impoundment, Fokes served a warrant on Reams’s property and the equines were inspected by a veterinarian. State law provided that Reams could challenge the impoundment, but Reams was unaware of that ability, of which the GDA did not inform her. In addition, state law provided Reams a right to seek judicial review of the GDA’s decision in state court. Reams brought suit in federal court against Fokes and GDA Commissioner Tommy Irvin (defendant), alleging that they violated her procedural due process rights. Specifically, Reams claimed that she had been entitled to a predeprivation hearing and personal notice of her right to challenge the impoundment under state law and that the process she was provided postdeprivation was insufficient. The district court granted the defendants’ motion for summary judgment, finding that they had qualified immunity. Reams appealed.
Rule of Law
Issue
Holding and Reasoning (Birch, J.)
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