Harding v. Layton – Do It For The Caselaw

Holding: The Eleventh Circuit affirmed the district court's grant of summary judgment, holding that the sheriff was not liable for sexual harassment by a non-supervisor and that the sergeant had probable cause to arrest the plaintiff.
Standard: Summary judgment standard; Fourth Amendment probable cause; Title VII supervisor liability
Vote: Per Curiam opinion affirming the district court.
Practical effect: The ruling reinforces that employers are not vicariously liable for harassment by non-supervisors without notice and that officers are protected by qualified immunity when they have probable cause to arrest individuals who falsely claim law enforcement authority.

Harding v. Layton

July 24, 2026 ·25-12350 ·Per Curiam · By James Taylor

The Eleventh Circuit affirmed summary judgment for law enforcement officials in a civil rights suit brought by a former detention deputy. The court held that the sheriff was not liable for sexual harassment by a non-supervisor and that a sergeant had probable cause to arrest the plaintiff for impersonating an officer.

Background

David Harding, a former detention deputy, sued Sheriff Dennis Lemma and Sergeant Alan Layton. He alleged sexual harassment by a lieutenant, Charles Albrecht, and malicious prosecution by Layton following Harding’s arrest for impersonating a deputy sheriff. The district court granted summary judgment for the defendants.

The court’s reasoning

The court affirmed the district court’s grant of summary judgment. Regarding the sexual harassment claims, the court found that Albrecht was not Harding’s supervisor and that the Sheriff had no actual or constructive notice of the harassment. Regarding the malicious prosecution and unlawful seizure claims, the court found that Sergeant Layton had probable cause to arrest Harding for false personation of an official, false imprisonment, and battery. The court determined that Layton did not make intentional or reckless misstatements in the arrest affidavit and that Harding was not authorized to act as a deputy sheriff.

What it means going forward

The ruling reinforces that employers are not vicariously liable for harassment by non-supervisors without notice and that officers are protected by qualified immunity when they have probable cause to arrest individuals who falsely claim law enforcement authority.