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Shelby County Sheriff Floyd Bonner and Chief Jailer Kirk Fields, two top officials who oversee the Shelby County Jail at 201 Poplar, have been dismissed from a civil lawsuit filed by the family of an inmate who was fatally stabbed inside a courtroom holding area.
Though the two co-defendants were dismissed from the case on Aug. 13, the lawsuit will remain active as Shelby County, as a governing body, was also sued and did not file a motion to dismiss.
The lawsuit was filed in January, about three months after 201 Poplar inmate Deion Byrd was stabbed in the neck by another inmate .
Shortly after it was filed, Bonner and Fields argued the case against them should be dismissed, citing four reasons in the motion to dismiss.
“One, the claims fail to make specific allegations about how defendants were personally involved in the deprivation of Byrd’s rights,” the ruling read. “Two, on the supervisory-liability claims, plaintiffs do not allege that defendants ‘encouraged the specific incident of misconduct or in some other way directly participated in it.’ Three, on the deliberate-indifference claims, plaintiffs do not plead, with particularity, facts that demonstrate defendants were deliberately indifferent to the conditions and risks Byrd faced. Four, defendants are entitled to qualified immunity because plaintiffs fail to plead with specificity what conduct was unconstitutional and what clearly established right was violated.”
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Judge Samuel H. Mays Jr. in his ruling found that attorneys for Byrd’s family had “not plausibly alleged that Bonner violated Byrd’s Fourteenth Amendment rights by failing to protect Byrd from detainee-on-detainee violence.” In supporting that conclusion, Mays said the lawsuit did not allege one of Bonner’s employees acted unconstitutionally and that Bonner knew or approved of the conduct.
Similar reasoning was used by the judge to explain why the claims against Fields also failed.
The general allegation that Bonner and Fields knew of the jail’s “dangerous conditions” and the two officials did not move to quell it did not sway the judge’s opinion for the deliberate indifference claims. In dismissing those claims against Bonner and Fields, the judge found that Bonner and Fields did not make “any intentional decisions about Byrd’s relevant conditions of confinement.”
The claims made against Bonner and Fields in the individual capacities failed, according to the ruling, because they do not involve “personal involvement” and “are more appropriately classified as claims against defendants in their official capacities, and therefore as claims of municipal liability.”
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Since the other claims were dismissed, the judge did not need to rule as to whether qualified immunity applied in the case, the ruling read.
Bonner and Fields had also filed a motion to stay the case while waiting for a ruling on the motion to dismiss. That motion was denied as moot, as it was no longer necessary since Bonner and Fields were dismissed from the lawsuit.
Though one in a number of active lawsuits against the Shelby County Jail, and Bonner by proxy, this was the first case to see a major motion ruled on. Byrd's family had retained notable civil rights attorney Ben Crump days after he was killed.
What happened to Deion Byrd at the jail?
Byrd was set for a report date the morning of Oct. 26, 2023, that was meant to take place inside Shelby County Criminal Court Division 1. He was in custody at the time and had to be brought up from the jail.
He was one of multiple Shelby County Jail inmates who had been brought up to Criminal Court Division 1 for separate court appearances at about 9:20 a.m., though Byrd was walked into court from a separate courtroom, which is commonly done when the elevator to the holding area does not work.
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Byrd was escorted, along with multiple other inmates, through the public waiting area of 201 Poplar's criminal court.
Minutes after inmates were brought into that holding area, yelling could be heard by a reporter for The Commercial Appeal, who was in the courtroom that morning, followed by a number of bailiffs rushing into the room.
The man who was stabbed, later identified as Byrd, was eventually escorted out, holding his hand over his neck and mouth area. It was unclear where he was exactly stabbed. He was taken to Regional One Health and ultimately died there.
Minutes later, another man was pulled from the holding area and was yelling at the bailiffs as they escorted him away. That man was later identified as Donnie Clay, and he has since been charged with first-degree murder .
"Witnesses stated that Deion Byrd approached the cell doorway and accused Donnie Clay of breaking into his home," the affidavit attached to Clay's charging documents read. "Clay denied the accusation and Deion Byrd spit in Clay's face. Clay said, 'I'm gonna kill you now,' and pulled a sharpened piece of metal from his waistband and chased Byrd into a nearby interview room a few feet away."
Clay then stabbed Byrd in the neck "at least once" with the makeshift knife, after which Byrd ran from the interview room and reached the door to the courtroom as a deputy entered the area, the affidavit said, and Clay threw the knife on the floor.
After the deputy saw Byrd bleeding from the neck, the affidavit said Clay proceeded to get on his knees and place his hands behind his head.
"The makeshift knife was recovered from the hallway floor," the affidavit said. "A large amount of blood was on the floor in the interview room, as well as blood in the hallway between the interview room and holding cell."
Four days after the fatal stabbing, Bonner said that there would be an investigation into "internal failures" that led to Byrd getting stabbed. It is still unclear how Clay got the makeshift knife from the jail to the courtroom.
This article originally appeared on Memphis Commercial Appeal: Sheriff, chief jailer dismissed from lawsuit over Shelby Co. Jail inmate stabbed in courtroom
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