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Civil rights Keyed to Jeffries, 5th Ed.
Board of County Commissioners of Bryan County v. Brown
Citation:
520 U.S. 397 (1997)Facts
Jill Brown and her husband were driving in Oklahoma when they approached a police checkpoint. Mr. Brown decided to avoid the checkpoint and return to Texas. Bryan County deputies, including Reserve Deputy Stacy Burns, pursued them. After stopping the vehicle, Burns ordered Mrs. Brown to exit. When she did not comply, Burns used an “arm bar” technique to forcibly remove her from the vehicle, causing severe knee injuries that required surgery. Burns was the nephew of Sheriff B.J. Moore, who had hired him despite Burns’ criminal record that included assault and battery, resisting arrest, public drunkenness, and multiple driving violations. Sheriff Moore had obtained Burns’ record but claimed he did not closely review it before hiring Burns. The jury found that the sheriff’s hiring policy was “so inadequate as to amount to deliberate indifference to the constitutional needs of the Plaintiff” and found the county liable under § 1983.
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