No Notice, No Liability: Eleventh Circuit Clarifies Supervisory/Municipal Standards and TVPRA “Knowingly Benefit” Requirement in Bridges v. Poe

Introduction

In a published decision addressing harrowing allegations of custodial sexual abuse, the Eleventh Circuit affirmed summary judgment for supervisory officials and a municipality, emphasizing that difficult facts do not change clear law on supervisory and municipal liability. In Bridges v. Poe (No. 22-12028, Oct. 17, 2025), six former inmates of the Jasper City Jail alleged widespread sexual abuse—primarily by jailer Rusty Boyd—and sued Chief of Police J.C. Poe, Chief Jailer Deborah Johnson, jailer Dennis Buzbee, and the City of Jasper under 42 U.S.C. § 1983 and the Trafficking Victims Protection Reauthorization Act (TVPRA), among other claims. The plaintiffs did not sue Boyd.

The central issues were whether supervisors and the City could be liable under § 1983 (Eighth Amendment) without evidence they knew of and tolerated a custom or policy of sexual abuse, whether failure-to-train theories could proceed when sexual misconduct is “obvious to all,” whether certain claims were time-barred under Alabama’s two-year limitations period, and whether the City could face TVPRA liability absent knowledge of a sex-trafficking venture. The panel (Judge Grant writing; Judge Abudu dissenting in part) affirmed, holding that a single report (involving a different officer) did not establish notice of a widespread custom, that failure-to-train claims cannot rest on obvious misconduct, that some claims were untimely, and that TVPRA claims fail where the City neither knowingly benefited from nor knew of any trafficking venture.

Summary of the Opinion

Individual-capacity § 1983 claims against Chief Poe and Chief Jailer Johnson: Qualified immunity applies. Plaintiffs failed to show the required causal connection between the supervisors’ actions and the constitutional violations because there was no evidence they had actual notice of multiple incidents or reports of sexual abuse. At most, Johnson heard of a single allegation involving a different officer (Jonathan Long) and a single inmate; Poe received no notice.
Failure-to-train theory: Rejected. There was a written policy prohibiting sexual contact with inmates, and sexual assault is “obvious to all” without specialized training. Absent actual or constructive notice of a training omission causing violations, supervisors and the City cannot be liable.
Official-capacity claims and Monell municipal liability: Rejected. No proof of a municipal custom, policy, or failure to train amounting to deliberate indifference, or that any such policy caused plaintiffs’ injuries.
Statute of limitations: Rainer’s and Mann’s § 1983 claims were untimely under Alabama’s two-year period; accrual occurred by the last assault (or at latest, release). Alabama’s Williams-Coleman Act tolling provision does not apply to § 1983 claims not brought under that act.
TVPRA claims against the City: Rejected. Plaintiffs did not show the City “knowingly benefited” from a venture that it knew or should have known violated the TVPRA; alleged trustee-labor benefits are insufficient without knowledge of the venture.

Factual Background

The Jasper City Jail was overseen by Chief of Police Poe (ultimate authority) and run day-to-day by Chief Jailer Johnson (training, compliance, logs, handling complaints). Jailers included defendants Buzbee and non-defendant Boyd (the primary alleged abuser). The jail used a trustee program to assign inmates to work details; disputes existed over who selected trustees. Policies barred sexual fraternization with inmates, prohibited abuse, and required logging incidents. Inmates could submit grievances via kiosks accessible only to upper administrators (not line jailers).

Plaintiffs alleged a pattern of sexual abuse mainly by Boyd (Goodson, Rainer, Dunn, Mann, and Tessener), with Bridges alleging abuse by Buzbee. Plaintiffs said kiosks were often down or not private and reported a climate discouraging complaints. One jailer (Softley) said she told Johnson that another officer (Long) was sexually assaulting Tessener; Johnson allegedly responded that she had told Long he would get caught. Johnson conceded hearing rumors that Long engaged in “talking dirty” and inappropriate advances. No direct evidence showed Poe or Johnson received reports of Boyd’s abuse before the state investigation.

In January 2018, the Alabama State Bureau of Investigation opened an inquiry; Poe placed Boyd on leave and Boyd resigned. The trustee program was suspended; later, Boyd was indicted for unlawful sexual conduct with a person in custody under Alabama law.

Analysis

Precedents Cited and Their Influence

Monell v. Department of Social Services, 436 U.S. 658: Establishes that municipalities are liable only for constitutional violations caused by an official policy or custom; respondeat superior does not apply. The court used Monell to reject municipal liability absent a custom/policy and causation.
Cottone v. Jenne, 326 F.3d 1352, and Piazza v. Jefferson County, 923 F.3d 947: Define supervisory liability and require a causal connection between a supervisor’s actions and the violation, typically by showing a custom/policy reflecting deliberate indifference. Piazza articulates the need for notice of multiple incidents or reports.
Craig v. Floyd County, 643 F.3d 1306, and Goebert v. Lee County, 510 F.3d 1312: Emphasize that single incidents cannot establish a custom or policy; plaintiffs must show a persistent, widespread practice akin to law.
Goodman v. Kimbrough, 718 F.3d 1325, and Wade v. McDade, 106 F.4th 1251 (en banc 2024): Clarify deliberate indifference in the Eighth Amendment context, requiring subjective awareness of a substantial risk to the inmate and objectively unreasonable response.
City of Canton v. Harris, 489 U.S. 378, and Connick v. Thompson, 563 U.S. 51: Set the standard for failure-to-train liability—deliberate indifference shown typically by a pattern of similar violations and notice of a specific omission.
Sewell v. Town of Lake Hamilton, 117 F.3d 488: Holds that failure-to-train does not create liability where the proper response is obvious without training.
Doe #1 v. Red Roof Inns, Inc., 21 F.4th 714: Defines elements for civil TVPRA § 1595 liability—knowingly benefits, participation in a venture, venture violated TVPRA as to the plaintiff, and actual/constructive knowledge of that violation. The court relied on Red Roof to hold that the City neither “knowingly benefited” nor had the requisite knowledge of any venture.
Wallace v. Kato, 549 U.S. 384, and Alabama limitations law: Guide accrual and the two-year statute for § 1983 claims; the court applied these to find Rainer’s and Mann’s claims time-barred.

Legal Reasoning

1) Supervisory liability: custom/policy and deliberate indifference

The court reiterated that supervisory liability without personal participation is “extremely rigorous.” A plaintiff must show the supervisor’s custom or policy caused the violation and reflected deliberate indifference, which in turn requires the supervisor’s subjective awareness of a substantial risk of serious harm. In practice, this means showing the supervisor knew of multiple incidents or multiple reports of prior misconduct by a particular employee, or of a widespread practice that is the functional equivalent of policy.

Applying that standard, the court found:

As to Chief Poe: No notice. Even assuming receipt of a letter stating the inmate did not like “the way Rusty [Boyd] would do things,” the letter did not reference sexual misconduct or a broader issue. Poe testified he would have acted immediately upon any notice of sexual misconduct and learned of allegations only when state investigators contacted him in January 2018.
As to Chief Jailer Johnson: At most, one reported allegation about a different officer (Long) and a single inmate (Tessener), and rumors of “talking dirty” or inappropriate advances. A single report—even if credited—cannot establish a custom or policy of tolerating sexual abuse. The record showed no multiple reports of similar sexual misconduct provided to Johnson before the alleged assaults, and several plaintiffs conceded they did not report to supervisors.

2) Failure-to-train theory

The court framed failure-to-train liability under City of Canton and Connick: there must be notice that a particular omission in training caused violations, typically by a pattern of similar incidents. The claim failed because:

The jail’s internal manual explicitly prohibited sexual contact and abuse of inmates and required logging of safety incidents. Some employees had received sexual-harassment training; others had on-the-job training.
Neither Poe nor Johnson had actual or constructive notice that a training omission caused sexual abuse.
Critically, sexual assault by jailers is “obvious to all” without training. Where misconduct is manifestly forbidden, failure-to-train cannot imply deliberate indifference.

3) Municipal liability (official-capacity claims)

Treating official-capacity claims as suits against the City, the court applied Monell. Plaintiffs failed to prove a municipal custom or policy that constituted deliberate indifference or that caused the violation. A single allegation reaching Johnson did not amount to a persistent, widespread practice. The same “obviousness” rationale defeated failure-to-train against the City.

4) Statute of limitations and accrual

Alabama’s two-year personal-injury limitations period applies to § 1983 claims. Under federal accrual rules, the claims accrued when plaintiffs had a complete and present cause of action—no later than the last assault or release from custody. Rainer’s and Mann’s filings were outside two years. The court rejected reliance on Alabama’s Williams-Coleman Act tolling because plaintiffs did not sue under that statute and its tolling applies only to suits “for offenses defined by this article.”

5) TVPRA liability against the City

The court applied Red Roof to the TVPRA claims: a plaintiff must show the defendant (1) knowingly benefited, (2) from participating in a venture, (3) that violated the TVPRA as to the plaintiff, and (4) the defendant had actual or constructive knowledge that the venture violated the TVPRA as to the plaintiff. The court rejected the theory that the City “benefited” through free trustee labor because:

City officials were unaware of any trustee-for-sex scheme; without knowledge of the venture, the City could not “knowingly benefit.”
Even if trustee labor conferred incidental savings, there was no evidence the City knew or should have known of a venture violating the TVPRA as to these plaintiffs.

The Dissent’s Perspective (Abudu, J.)

Judge Abudu would have allowed Eighth Amendment claims against Johnson (individual and official capacities) to proceed to trial, citing:

Evidence that a subordinate (Softley) told Johnson that officer Long was sexually assaulting inmate Tessener, Johnson’s reported response that she had warned Long he would be caught, and a contemporaneous written statement reflecting Johnson had heard such allegations “a while back.”
Evidence that Johnson discouraged kiosk grievances and that inmates feared retaliation, supporting a custom of ignoring or suppressing complaints.
Under Farmer and Wade, a jury could find Johnson had subjective knowledge of a substantial risk of sexual assault and responded unreasonably by doing nothing; Poe’s immediate response once notified (placing Boyd on leave, facilitating the state investigation, transferring an inmate) contrasted sharply with Johnson’s inaction.
For official-capacity/Monell, cumulative evidence of discouraged reporting, absence of PREA-compliant procedures, and knowledge of misconduct could show deliberate indifference in training and supervision.

Impact and Practical Implications

For supervisory and municipal liability in custodial sexual abuse cases

The decision underscores a demanding notice requirement: plaintiffs must marshal evidence that supervisors were informed of multiple incidents or had repeated complaints about an employee or a pervasive practice. A single report involving a different officer is insufficient to establish a “custom” or “policy” or deliberate indifference.
Plaintiffs should prioritize developing a record of notice: grievance logs, letters to policymakers, emails, incident logs, prior investigations, and testimony showing repeated reports. Absent such proof, even severe wrongdoing by subordinates may not translate into supervisory or municipal liability.
The panel’s reliance on Wade (en banc) highlights a sharpened focus on the defendant official’s subjective awareness that “his own actions or inactions” posed a substantial risk to the plaintiff, plus an objectively unreasonable response.

On failure-to-train claims

Where the underlying misconduct is categorically obvious (e.g., sexual assault by custodial staff), failure-to-train claims face an elevated hurdle. A written policy forbidding the conduct and general common-sense awareness by employees undercut deliberate indifference absent a known pattern indicating training deficiencies.
Municipalities should still document sexual misconduct training, reporting protocols, and PREA-aligned procedures, but this decision signals that the lack of specialized training on “do not sexually assault inmates” will not, by itself, establish liability.

For TVPRA civil suits against public entities

The court’s application of Red Roof clarifies that “knowingly benefits” is not satisfied by incidental or unknowing cost savings. Plaintiffs must connect the benefit to the defendant’s knowing participation in a venture and establish actual or constructive knowledge that the venture violated the TVPRA as to the plaintiff.
Suits premised on institutional labor arrangements (like trustee programs) must show officials’ knowledge that the program functioned as a sex-trafficking venture, not merely that the institution received labor benefits.

Limitations and accrual

The panel’s straightforward application of Alabama’s two-year statute and federal accrual rules reinforces the need to file within two years of the last actionable injury. Attempts to import tolling from state anti-trafficking statutes will fail unless the plaintiff actually sues under that article.
Counsel should evaluate accrual at the time of the last assault and consider equitable doctrines separately; introduce and preserve tolling theories in the district court.

Complex Concepts Simplified

Qualified immunity: Shields individual officials from damages unless they violate clearly established law. Even when the right is clearly established (e.g., to be free from sexual abuse in custody), plaintiffs must show the particular official’s conduct violated that right under governing standards.
Supervisory liability: Without personal participation, a supervisor is liable only if her own actions—e.g., maintaining a custom/policy or failing to train with deliberate indifference—caused the violation. Requires notice and deliberate indifference.
Monell liability: A city is liable only for its own policies or customs that cause a violation; not for employees’ torts via respondeat superior. Proof typically involves established practices “so permanent and well settled” as to have the force of law, or deliberate-indifference failure to train.
Deliberate indifference: In the Eighth Amendment context, the official must be subjectively aware of a substantial risk of serious harm and respond unreasonably in light of that risk (Wade/Farmer).
Failure to train: Requires showing the municipality or supervisor had notice that a specific training omission caused constitutional violations (often shown by a pattern) and nevertheless chose to retain the deficient program.
Official vs. individual capacity: Official-capacity suits are effectively suits against the government entity; individual-capacity suits target the personal liability of the official for her own unconstitutional conduct.
TVPRA § 1595: A civil claim requires that the defendant knowingly benefited from participation in a venture that violated the TVPRA as to the plaintiff, with actual or constructive knowledge of that violation. Incidental benefits without knowledge do not suffice.
Accrual and statute of limitations: § 1983 claims accrue when the plaintiff can sue—when the injury is complete and knowable. Alabama’s two-year period governs personal injury claims, including § 1983 claims arising in Alabama.

Conclusion

Bridges v. Poe reinforces core constraints on § 1983 supervisory and municipal liability and clarifies the knowledge and benefit elements for TVPRA claims against public entities. The court held that a single report of misconduct involving a different officer cannot establish a custom or policy or deliberate indifference; that failure-to-train claims falter where the forbidden conduct is obvious and a written policy exists; that certain claims were time-barred under clear accrual rules; and that TVPRA liability requires proof the City knowingly benefited from, and knew or should have known about, a trafficking venture.

The dissent underscores the evidentiary stakes: where there is proof a policymaker was told about sexual assaults and did nothing, a jury trial may be warranted. Going forward, plaintiffs alleging custodial sexual abuse must build robust records of supervisory notice and institutional response; municipalities should ensure accessible reporting systems, enforce logging and escalation protocols, and document training and PREA-aligned practices to mitigate risk and protect inmates. The decision’s message is stark: without notice, there is no supervisory or municipal liability—even in the face of grievous underlying abuse.