In Leahy v. Conant,[1] the supreme court held that public officials have qualified immunity from civil liability when there is no showing that they act unreasonably in following a government directive. An Alaska Department of Corrections (DOC) directive prohibited mail from being sent between prisoners. Leahy, a Muslim inmate, filed suit against two correctional facility superintendents, Conant and Sullivan, alleging the DOC directive placed a substantial burden on his religious rights. Leahy’s motion for summary judgment, which again contended the directive had violated his religious rights, was denied and Leahy appealed. The court affirmed the lower court’s decision, holding that public officials have qualified immunity from civil liability insofar as their conduct does not clearly violate statutory or constitutional rights which a reasonable person would be aware of. The court reasoned that because regulations similar to the restriction on prisoner mail had been found constitutional, it would be inappropriate to find that Conant and Sullivan’s conduct pursuant to the restriction clearly violated constitutional rights which a reasonable person would be aware of. The supreme court affirmed, holding that public officials have qualified immunity from civil liability when there is no showing that they act unreasonably in following a government directive.
[1] 436 P.3d 1039 (Alaska 2019).
