Former Hamblen County Jail inmate Zachery Beck cannot sue Sheriff Esco Jarnagin in his personal capacity for injuries Beck sustained while incarcerated in 2016, a federal appeals court ruled on Monday.
If the U.S. Court of Appeals for the Sixth Circuit had upheld the recommendations of U.S. District Judge Travis McDonough – that Jarnigan was “deliberately indifferent” to inmate-on-inmate violence, the sheriff could have been held personally and financially responsible for Beck’s injuries.
“Sheriff Jarnagin had no direct involvement in Beck’s detention and (federal law) does not impose vicarious liability on supervisors for their subordinates actions … Beck has identified no evidence suggesting Jarnagin had any personal knowledge of Beck’s specific situation,” the appeals court decision states.
“Jarnagin, for example, did not help choose the cell in which Beck was detained,” the opinion further states. “Jarnagin also had not heard the warnings about placing Beck in a cell with (his alleged assailant.) And he did not know of any of Beck’s personal characteristics that might make him more susceptible to assault.”
The federal damages lawsuit is still pending in U.S. District Court in Greeneville. Monday’s 15-page opinion means only that Jarnagin cannot be held personally responsible. The legal proceedings in Greeneville were stayed until Sixth Circuit judges decided the personal-responsibility issue.
Beck was incarcerated on drug charges in April 2016 when he allegedly sustained serious injuries. An inmate allegedly reached below Beck’s pants in an effort to locate drugs that he believed Beck might have hidden inside himself. The following day, another inmate broke into Beck’s cell and repeatedly punched him the throat, according to the opinion.
Prosecutors found insufficient evidence to file charges against the alleged assailants, according to the opinion.