Case Citator › Wayne v. Jarvis

Wayne v. Jarvis

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

Overruled in part
Court
Eleventh Circuit
Citation
197 F.3d 1098
Decided
Confirmed treatments
1
Flagged citations read
40 of 40
Citing cases (total)
40
Treatment dates
2003
Overruled in part
A reviewed court has overruled part of this case’s holding. Wayne v. Jarvis was overruled in part on whether a Georgia sheriff acts for the county when setting jail force policy and training or disciplining deputies for that policy. The Eleventh Circuit's en banc decision in Manders v. Lee rejected that part of Wayne's official-capacity reasoning.
More on how this was screened

Wayne's separate Rule 15(c) holding about replacing John Doe defendants remains in use. All 40 flagged citations have been read; the confirmed treatment is 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.

40 later cases cite Wayne v. Jarvis; 40 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 Wayne v. Jarvis?

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 en banc Eleventh Circuit overruled Wayne's implication that Georgia sheriffs act for counties when setting jail force policy and training or disciplining deputies for that policy.

    Manders v. Lee · Eleventh Circuit (en banc) · filed

    In prior § 1983 cases, we merely accepted official capacity suits against Georgia sheriffs as suits against their respective counties. See, e.g., Alexander v. Fulton County, 207 F.3d 1303, 1322 n.14 (11th Cir. 2000); Wayne v. Jarvis, 197 F.3d 1098, 1105 (11th Cir. 1999). In these cases, we did not decide whether, under Georgia law, sheriffs are agents for the State or the counties, and it does not appear the parties raised the question. To the extent that our prior decisions state or imply that Georgia sheriffs act for counties regarding the particular functions in issue–force policy and training and disciplining of deputies in that regard–we overrule those decisions.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Wayne v. Jarvis 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