Supreme Court of Arkansas

Reginald R. Early, Appellant v. Keith Crockett; Clayborn Carroll; Roberta Lewis; and Lamon Mayo, Appellees

June 19, 20142014 Ark. LEXIS 379

Summary

The court affirmed dismissal of the official-capacity claim seeking a declaration that prison officials previously violated Early's constitutional rights because the requested declaration was retrospective, and the requested injunction appeared moot. It reversed and remanded dismissal of the individual-capacity section 1983 failure-to-protect claim because state statutory immunity could not resolve the federal claim and the circuit court had not applied the deliberate-indifference and qualified-immunity standards. It affirmed dismissal of the individual-capacity negligence claim because the record contained no evidence of malice sufficient to overcome statutory immunity.