Defining the Scope of Professional Judgment in Civil Detainee Deliberate Indifference Claims under the Fourteenth Amendment

Introduction

This commentary examines the Eleventh Circuit’s decision in Tonnie Nealy v. Donald Sawyer, No. 24-10182 (11th Cir. May 21, 2025), which clarifies the standard for deliberate indifference claims brought by civil detainees under the Fourteenth Amendment. At issue were the housing decisions of two officials—Donald Sawyer (Center Administrator) and Emily Salema (Clinical Director)—at the Florida Civil Commitment Center. Plaintiff-appellant Tonnie Nealy, a pro se civil detainee, alleged that defendants violated his right to safe conditions by placing a violent resident (“RN”) in the same dormitory, leading to a physical assault. The Eleventh Circuit granted summary judgment for the defendants, holding that their decisions fell within the “presumptively valid” range of professional judgment.

Summary of the Judgment

In a per curiam opinion, the Court of Appeals affirmed the district court’s grant of summary judgment. Applying the standard for civil detainee claims under the Fourteenth Amendment, the panel held that:

Decisions by commitment‐center professionals are presumptively valid unless they constitute a “substantial departure from accepted professional judgment, practice, or standards.”
The record showed that the Center attempted to transfer RN to county jail, provided twenty-four-hour surveillance and enhanced security measures in Lakes Dorm, and reasonably assessed that one security officer could maintain safety.
Plaintiff’s conclusory denials and unsupported allegations could not overcome the defendants’ affidavits and records under Rule 56.
Accordingly, no genuine dispute of material fact existed as to deliberate indifference, and summary judgment was proper.

Analysis

Precedents Cited

The court’s reasoning drew heavily on several Eleventh Circuit and Supreme Court decisions:

Bilateral v. Geo Care, LLC, 981 F.3d 903 (11th Cir. 2020): Established that professional judgments at a commitment center are “presumptively valid” and defendants are liable only for decisions that substantially depart from accepted professional standards.
Dolihite v. Maughon by & through Videon, 74 F.3d 1027 (11th Cir. 1996): Recognized that Fourteenth Amendment protects civil detainees’ right to safe conditions of confinement.
Pesci v. Budz, 730 F.3d 1291 (11th Cir. 2013): Emphasized the facility’s legitimate interest in security and rehabilitation, and that staff are best equipped to make housing decisions.
Youngberg v. Romeo, 457 U.S. 307 (1982): Held that social‐institution professionals enjoy broad deference, and courts should not second‐guess reasonable professional judgments.
Burton v. Tampa Housing Auth., 271 F.3d 1274 (11th Cir. 2001): Reaffirmed the standard for summary judgment—conclusory allegations cannot rebut undisputed affidavits.

Legal Reasoning

The Eleventh Circuit applied a two‐step framework:

Determine if the Fourteenth Amendment confers a right to safe conditions for civil detainees (it does).
Assess whether the defendants’ actions were a substantial departure from professional judgment. Under Bilal, the burden rests with the plaintiff to produce evidence that the housing decisions were objectively unreasonable.

Here, defendants Sawyer and Salema submitted detailed affidavits and institutional records showing:

The unsuccessful effort to transfer RN to custody of the sheriff’s department.
Enhanced security protocols in Lakes Dorm (constant surveillance, video monitoring, rapid‐response alerts, staff‐escorted movements).
A reasoned judgment by the security director that one guard could maintain safety given the facility’s design and procedures.

Nealy failed to provide admissible evidence disputing these facts—relying instead on conclusory denials and unverified allegations. Under Federal Rule 56(e), conclusory responses without supporting materials cannot create a triable issue.

Impact

This decision reinforces and refines the Eleventh Circuit’s deference to professional judgment in civil‐detainee litigation:

It underscores that records, affidavits, and institutional policies carry decisive weight at the summary‐judgment stage.
Plaintiffs must produce concrete evidence of a professional’s substantial deviation from accepted standards, rather than assertions of indifference.
Facilities and their staff gain clearer guidance on documentation and procedural safeguards needed to defend against deliberate indifference claims.
The ruling may deter marginal claims where detainees cannot show any professional misjudgment beyond tragic outcomes.

Complex Concepts Simplified

Deliberate Indifference: A legal standard requiring proof that officials knew of and disregarded an excessive risk to detainees’ health or safety.
Professional Judgment Presumption: Courts assume that reasonable professional decisions—such as housing assignments—are valid; plaintiffs must show a significant departure from accepted norms.
Summary Judgment: A procedural tool under Rule 56 allowing immediate judgment for a party when there is no genuine dispute of material fact.
Baker Act Commitment: A Florida statute (§ 394.463) permitting involuntary civil commitment of individuals with mental illness posing a danger to self or others. (“RN” was not actually Baker Acted.)
Secure Management Status: A short‐term (up to 72 hours) restrictive measure for detainees who pose an imminent threat, triggering room confinement and heightened supervision.

Conclusion

Nealy v. Sawyer cements the Eleventh Circuit’s framework for Fourteenth Amendment deliberate indifference claims by civil detainees, emphasizing deference to commitment‐center professionals and the high evidentiary hurdle for plaintiffs. The decision clarifies that, absent clear proof of a substantial deviation from accepted professional judgment, courts will grant summary judgment to officials whose security and housing determinations rest on documented protocols and reasoned assessment. This precedent will shape future litigation over detainee safety, reinforcing that sound professional practice—not undesirable outcomes—governs constitutional liability.