Background
This appeal arises from a fatal traffic accident in Charleston County, South Carolina, involving deputies responding to a non-emergency call. Plaintiffs, representing the estates of three women who died in the crash, sued the deputies and the Charleston County Sheriff’s Office under Section nineteen eighty-three. The Sheriff’s Office moved to dismiss, arguing it is an arm of the state and immune from suit under the Eleventh Amendment. The district court granted the motion, relying on Fourth Circuit precedent in Cromer v. Brown.
The court’s reasoning
The Supreme Court had previously vacated the Fourth Circuit’s prior decision in this case and remanded it for reconsideration in light of Galette v. New Jersey Transit Corp. The Fourth Circuit concluded that Galette did not supersede its controlling precedent regarding the status of South Carolina sheriff’s offices. The court reaffirmed that under Cromer v. Brown, South Carolina county sheriff’s offices are arms of the state. The court noted that while the plaintiffs requested a new analysis of the four-factor test from Ram Ditta, the panel is bound by the mechanical mandate of prior circuit precedent and cannot undertake a new analysis when binding precedent exists.
What it means going forward
The ruling confirms that plaintiffs cannot sue the Charleston County Sheriff’s Office directly under Section nineteen eighty-three for constitutional violations, as the office is shielded by state sovereign immunity. Litigation must proceed against individual deputies in their personal capacities or against the county itself if it is not considered an arm of the state.