Cementing Good Law by Tolerating Bad Outcomes: Examining the Eighth Circuit's Commitment to Upholding the Defense of Qualified Immunity for Prison Officials in Kulkay v. Roy

Abstract

On February 2, 2017, the U.S. Court of Appeals for the Eighth Circuit decided Kulkay v. Roy and affirmed the U.S. District Court for the District of Minnesota’s dismissal of plaintiff’s civil rights claims under the Eighth and Fourteenth Amendments. The plaintiff, a former inmate at a Minnesota correctional facility, sued the correctional facility and related officials for failing to install safety features on a piece of machinery and not providing him with adequate usage training after he suffered damage to his hand while operating the beam saw. The district court held that the plaintiff inmate failed to state a claim under the Eighth Amendment due to qualified immunity. The Eighth Circuit affirmed this decision, holding that the prison officials did not exhibit deliberate indifference and therefore were entitled to the defense of qualified immunity. The Eighth Circuit based this reasoning in the fact that the plaintiff failed to show that the prison officials acted with deliberate indifference towards his health or safety. This comment argues that the Eighth Circuit was correct in re-emphasizing its commitment to the standard of deliberate indifference because the underlying policy motivations for the defense of qualified immunity dictate that a few bad outcomes, such as plaintiffs not receiving damages for harm caused to them, be tolerated in order to cement an otherwise good law.