Case Explained: Lakey, et al. v. Bryant, et al.

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-07-07

Docket: 6:20-CV-00152-RAW)

The Tenth Circuit affirmed the district court’s judgment in favor of Sheriff Chris Bryant, rejecting all claims brought by the Estate of Jared Lakey under 42 U.S.C. § 1983. The court held that Sheriff Bryant was entitled to qualified immunity in his individual capacity because the Estate failed to identify any controlling Supreme Court or Tenth Circuit precedent establishing that maintaining a Mutual Aid Policy requiring deputies to assist smaller agencies violated clearly established law. The court further affirmed summary judgment against the Estate’s municipal liability claim alleging an informal custom of excessive force, ruling that a single incident of misconduct is insufficient to prove the “widespread, persistent pattern” required for such liability, and noting that the Estate had waived any ratification theory. Regarding evidentiary rulings, the court determined that excluding evidence that Deputy Duggan was not criminally charged was harmless error because the excluded evidence was irrelevant to the claims actually submitted to the jury. Finally, the court affirmed the denial of spoliation sanctions under Federal Rule of Civil Procedure 37(e), finding that while the district court may have erred in placing the burden of proving prejudice on the Estate, any such error was harmless because the missing text messages could not have established liability for an informal custom absent evidence of a pattern of violations. The judgment is affirmed, leaving the Estate with no recovery from Sheriff Bryant.

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