McGuire v. Loudon County Jail et al.

After being brutally attacked by officers in the Loudon County Jail, Devin McGuire was prevented from holding them accountable in court because of a small technical misstep in his complaint form. The MacArthur Justice Center is fighting to ensure that complicated and confusing complaint forms do not prevent prisoners—particularly those without lawyers—from having their day in court to vindicate their rights. 

Mr. McGuire had just arrived at Loudon County Jail in Tennessee when three officers brutally assaulted him. They strapped him to a chair, beat him with handcuffs, knocked out his teeth, cracked his ribs, and left him alone and naked in a cell – all without provocation. 

Despite the officers threatening further violence if he “said anything,” Mr. McGuire filed a lawsuit against the officers, pro se – meaning he represented himself – in an effort to hold them accountable for the assault. Nine days after he filed, Mr. McGuire was the victim of another unprovoked attack, in which another officer stripped him naked, shackled him, put him in a chokehold, and dislocated his arm. 

Mr. McGuire’s brutal assault violated the Constitution. But when he filed suit, operating without the benefit of a lawyer, he made one small mistake: On the pro se complaint form he used to file his lawsuit, he checked the box indicating he wished to sue the defendants in their “official” capacities, rather than their “individual” capacities. An “official capacity” suit operates against the municipality itself rather than individual officers, but his complaint was clear that he intended to sue the officers themselves. 

Rather than recognize that Mr. McGuire plainly wished to sue the individual officers who had assaulted him, the district court dismissed Mr. McGuire’s complaint by holding him strictly to his check marks in the “official capacity” boxes. In so doing, it ignored the widely-acknowledged fact that the distinction between “individual” and “official” capacity lawsuits confuses lawyers, courts, and laypeople alike—and that the Sixth Circuit created a test to clear up that confusion for cases just like this one. 

Small, technical pleading missteps aren’t supposed to prevent meritorious claims from being heard, even in lawyered cases. That principle has even greater resonance in pro se cases like this one. The district court disregarded that mandate, and as a consequence, it prevented Mr. McGuire from obtaining any measure of accountability for the brutal assaults he alleges.  

The MacArthur Justice Center represents Mr. McGuire on appeal to the Sixth Circuit.