Background
Plaintiff Anthony Jefferson filed a civil-rights action under 42 U.S.C. § 1983, alleging violations of his Eighth and Fourteenth Amendment rights by officers at the El Dorado Correctional Facility. The defendants sought dismissal based on Eleventh Amendment and qualified immunity.
The court’s reasoning
The Tenth Circuit found that the district court’s denial of the defendants’ motion was not immediately appealable under the collateral-order doctrine. The court emphasized that the denial did not imperil a substantial public interest and that procedural requirements must be met.
Requiring public officers to comply with nononerous procedural requirements does not impair a substantial public interest.
Appellate Case: 25-3020 Document: 51-1 Date Filed: 06/08/2026 Page: 3
What it means going forward
The decision reinforces the requirement for defendants to comply with procedural rules before seeking interlocutory appeals on immunity grounds.