Case Citator › Samuel L. Pfannstiel v. City of Marion, Doyle Elliot and James A. Pearce, Mike Earl, Harvey Faulkner and Waldon Boecker, Etc.

Samuel L. Pfannstiel v. City of Marion, Doyle Elliot and James A. Pearce, Mike Earl, Harvey Faulkner and Waldon Boecker, Etc.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Fifth Circuit
Citation
918 F.2d 1178
Decided
Confirmed treatments
2
Flagged citations read
39 of 39
Citing cases (total)
39
Treatment dates
1992–1996
Overruled in part
A reviewed court has overruled part of this case’s holding. Pfannstiel v. City of Marion is no longer controlling on two issues, although later courts continue to apply its § 1983 conspiracy rule. All 39 flagged citations have been read.
More on how this was screened

Martin v. Thomas refused to follow Pfannstiel's excessive-force standard for conduct before Graham v. Connor. The Fifth Circuit sitting en banc in Hare v. City of Corinth replaced the objective standard for episodic denials of medical care with subjective deliberate indifference. Desroche v. Strain later described Pfannstiel's former standard and contrasted it with Hare. The two confirmed treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

39 later cases cite Samuel L. Pfannstiel v. City of Marion, Doyle Elliot and James A. Pearce, Mike Earl, Harvey Faulkner and Waldon Boecker, Etc.; 39 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Samuel L. Pfannstiel v. City of Marion, Doyle Elliot and James A. Pearce, Mike Earl, Harvey Faulkner and Waldon Boecker, Etc.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Fifth Circuit sitting en banc replaced Pfannstiel's objective medical-care standard for a jail official's episodic acts with subjective deliberate indifference.

    Hare v. City of Corinth, Miss. · Fifth Circuit (en banc) · filed

    Finding no constitutionally significant distinction between the rights of pretrial detainees and convicted inmates to basic human needs, including medical care and protection from violence or suicide, we conclude that a state jail official’s constitutional liability to pretrial detainees for episodic acts or omissions should be measured by a standard of subjective deliberate indifference as enunciated by the Supreme Court in Farmer.
    Read the full opinion on CourtListener →

Declined to follow

  • The Fifth Circuit refused to follow Pfannstiel's excessive-force standard for earlier conduct because it conflicted with an en banc decision applying Graham retroactively.

    Martin v. Thomas · Fifth Circuit · filed

    In Pfannstiel, we held that the Shillingford standard still applied. The Court, however, overlooked the fact that in Johnson also the incident had occurred before Graham while Shillingford was still in effect, but in Johnson, an en banc case, we applied the Graham standard.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Samuel L. Pfannstiel v. City of Marion, Doyle Elliot and James A. Pearce, Mike Earl, Harvey Faulkner and Waldon Boecker, Etc. and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace