Graves v. Lioi

After Cleaven Williams stabbed and killed his pregnant wife and the unborn child outside of a courthouse where she had just obtained a protective order against him, plaintiffs filed suit against defendant, alleging that he was responsible for Mrs. Williams' death because defendant enabled him to postpone his self-surrender on a misdemeanor arrest warrant, which provided Williams the opportunity to murder his wife. The Fourth Circuit previously affirmed the district court's denial of defendant's motion to dismiss the claims based on qualified immunity. Plaintiffs then amended the complaint to add another defendant, and the district court granted summary judgment to both defendants. Plaintiffs appealed.The court affirmed the district court's judgment and held that plaintiffs failed to present sufficient evidence that reasonable jurors could find by a preponderance of the evidence for her. In this case, plaintiffs' version of the events was not supported by sufficient evidence to permit a reasonable jury to conclude that defendants undertook any affirmative acts that would support liability for a state-created danger substantive due process claim. View "Graves v. Lioi" on Justia Law