Amy Coney Barrett Demolishes the Qualified Immunity Claim of a Detective Accused of Framing a Man for Murder
After William Rainsberger was arrested for murdering his 88-year-old mother, he spent two months in jail before he was released on bail. A year later, prosecutors dropped the case, citing a lack of evidence. That decision was not surprising, because Rainsberger’s arrest was based on a probable cause affidavit written by an Indianapolis detective who misrepresented crucial facts and omitted exculpatory information.
The detective, Charles Benner, nevertheless argued that Rainsberger could not sue him under 42 USC 1983, a federal statute that allows people to seek damages when government officials violate their constitutional rights. In a 2019 opinion, the U.S. Court of Appeals for the 7th Circuit demolished Benner’s argument that he was protected by qualified immunity, a court-invented doctrine that limits such claims to cases in which officials are accused of violating “clearly established” law.
That opinion is of special interest to critics of qualified immunity—which in many cases has protected police officers from liability for shocking behavior—because it was written by 7th Circuit Judge Amy Coney Barrett, who is reportedly the leading contender to replace Ruth Bader Ginsburg on the Supreme Court. In addition to supporting legislation that would limit or abolish qualified immunity, its critics hope the Supreme Court will reconsider the doctrine in an appropriate case. While the 7th Circuit’s decision in Rainsberger v. Benner does not reveal how Barrett would vote in such a case, it does suggest she is not the sort of judge who bends over backward to protect police officers accused of outrageous misconduct.
Ruth Rainsberger, who suffered from dementia, had three children. William was the most attentive, looking in on her every day, buying groceries for her, and helping her with her finances. When he visited her on a Tuesday afternoon in November 2013, according to his account, he found the door to her apartment unlocked and found his mother lying face down on the floor in a pool of blood, her head and shoulders covered by a bloody blanket. He called 911 and reported that someone had “bashed [his mother’s] head in.”
Benner zeroed in on William Rainsberger as his prime suspect early on, speculating that he had killed his mother for his share of the $80,000 to $100,000 in savings he and his siblings would inherit. Two months after the murder, Benner wrote a probable cause affidavit that local prosecutors deemed inadequate. Five months later, he wrote another affidavit that was nearly identical but included some new details. This time prosecutors agreed there was enough evidence to charge Rainsbe
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