Manders v. Lee’s Empirical Analysis
285 F.3d 983 · 2002
Citation profile
6 federal appellate ·
Relationships
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Monell v. Department of Social Services of City of New York · Mt. Healthy City School District Board of Education v. Doyle · Pennhurst State School and Hospital v. Halderman · Kentucky v. Graham · Will v. Michigan Department of State Police
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although sheriffs are designated “county officers,” the Georgia Constitution and Code afford counties no authority, role, or control over (a) sheriffs qualifications, minimum salary, law enforcement powers and duties, (b) the investigation and suspension of sheriffs, or (c) the training, supervision, and discipline of his deputies at the jail. Sheriffs are independent and separate from county boards to such a degree that Georgia courts have held that counties are not liable under state law for the actions of the sheriff or his deputy jailers. Indeed, the state has mandated that sheriffs alone hire and fire their own deputies and jailers. We recognize that counties set the total amount of sheriffs’ budgets and pay sheriffs’ salaries, but counties cannot reduce the sheriffs’ minimum salaries and cannot dictate how that budget is spent. Counties may waive the sheriffs’ sovereign immunity for motor-vehicle claims by purchasing insurance, but Eleventh Amendment precedent now makes clear that insurance or indemnification provided by a third party, such as the county, is not material to whether there is a risk of an adverse judgment or potential legal liability. Counties construct and maintain the county jails and must provide inmates certain necessities, but counties have no authority, role or control over the sheriffs’ use-of-force policies at the jail. Thus, on balance, we believe sheriffs are not agents of counties when performing their law enforcement duties as to use of force.”
1 later decision quote this exact passage · from the concurrence
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.