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Civil Rights: §1983-Wrongful Death-Official and Qualified Immunity

Staff Report//June 17, 2026//

Civil Rights: §1983-Wrongful Death-Official and Qualified Immunity

Staff Report//June 17, 2026//

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Defendants appealed the denial of their motions to dismiss under official and qualified immunity. Corey Coffelt took his own life while in administrative segregation in prison. Plaintiffs, his parents, filed wrongful death and §1983 claims against defendants. The district court denied defendants’ summary judgment motion on the wrongful death and deliberate indifference claims.

Where defendants’ alleged failures concerned duties that required discretionary judgment, official immunity barred the wrongful death claim, and any negligence by defendants did not rise to the level of deliberate indifference.

Judgment is reversed and remanded.

Headley v. Centurion of Missouri, LLC (MLW No. 84915/Case No. 25-1877 – 8 pages) (U.S. Court of Appeals, 8th Circuit, Benton, J.) Appealed from U.S. District Court, Eastern District of Missouri, Autrey, J. (Louis Joseph Capozzi III, AAG, St. Louis, MO for appellants; Robert Ryan Harding, former AAG, Jefferson City, MO on the brief) (Stephen L. Bishop, Kansas City, MO for appellees)

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