J.K.J. v. Polk County

M.J.J. and J.K.J. were inmates at Polk County Jail at various times between 2011 and 2014. Christensen admits he engaged in sexual acts with the women individually. He urged the women not to discuss his sexual advances; his assaults were kept hidden from jail officials until a former inmate reported her own sexual encounters with Christensen to an investigator in a neighboring county. An investigation led to Christensen pleading guilty to several counts of sexual assault. He is serving a 30‐year prison sentence. J.K.J. and M.J.J. sued Christensen and the county under 42 U.S.C. 1983, alleging Eighth and Fourteenth Amendment claims, with a state law negligence claim against the county. A jury found Christensen and the county liable and awarded each woman $2 million in compensatory damages. The jury also levied punitive damages against Christensen, $3,750,000 to each plaintiff. The Seventh Circuit affirmed as to Christensen. His assaults were predatory and knowingly criminal. The court reversed as to the county. To impose liability against the county for Christensen’s crimes, there must be evidence of an offending county policy, culpability, and causation. Christensen’s acts were reprehensible, but the evidence shows no connection between the assaults and any county policy. View "J.K.J. v. Polk County" on Justia Law