Kennell v. Gates

Appeal from the United States District Court for the Eastern District of Missouri. Submitted: February 16, 2000 Officer Diahann Gates of the St. Louis Metropolitan Police Department appeals from the jury verdict finding her liable under 42 U.S.C. § 1983 (Supp. III 1997) for plaintiff Sharon Denise Kennell's six-day confinement on an arrest warrant issued for Sharon's sister, Deborah Kennell. We must decide whether evidence that Gates was sent a report over an in-house computer message system indicating that the wrong sister was in custody is sufficient to allow a jury to find that Gates had actual knowledge of a substantial risk that Sharon was mistakenly imprisoned. We hold that the evidence was sufficient, and we affirm.