The Ninth Circuit Court of Appeals issued a split ruling in *Crawley v. Williams*, denying qualified immunity protections to five Nevada Department of Corrections officers while partially reversing other aspects of the lower court's decision. The memorandum opinion, filed Jan. 16, 2026, addresses constitutional violations alleged by Daine Anton Crawley, an individual incarcerated at a Nevada state facility.
The case involves NDOC employees Richard Ashcraft, Kody Holloway, Robert Robison, Robert Suwe, and Brian Williams, who appealed the U.S. District Court for the District of Nevada's denial of their qualified immunity defense. Magistrate Judge Craig S. Denney had previously granted summary judgment in favor of Crawley on certain claims while denying the corrections officers' assertion of qualified immunity.
Qualified immunity is a legal doctrine that protects government officials from civil lawsuits unless they violated clearly established constitutional rights that a reasonable person would have known about. The doctrine has become increasingly scrutinized in recent years, particularly in cases involving law enforcement and corrections personnel.
The Ninth Circuit panel, consisting of Circuit Judges S.R. Thomas, Bress, and Mendoza, reviewed the case de novo following oral arguments held Nov. 21, 2025, in San Francisco. The court applied the standard established in *Desire, LLC v. Manna Textiles, Inc.*, which requires courts to review grants of summary judgment without deference to the lower court's findings.
While the full details of Crawley's allegations are not specified in the available court documents, the case represents another instance where federal appellate courts have limited the scope of qualified immunity protections for corrections officials. The Eighth Amendment's prohibition on cruel and unusual punishment has been the basis for numerous prisoner rights lawsuits against state corrections departments nationwide.
The appellate court's jurisdiction stems from the qualified immunity denial under 28 U.S.C. § 1291, as established in *Wilkins v. City of Oakland* (9th Cir. 2003). This jurisdictional basis allows immediate appeals of qualified immunity denials, even before final judgment in the underlying case, recognizing that immunity is meant to protect officials from the burdens of litigation itself.
The Nevada Department of Corrections has faced multiple federal lawsuits in recent years involving conditions of confinement and treatment of incarcerated individuals. State corrections systems across the country have increasingly found themselves defending against constitutional challenges as courts have become more willing to scrutinize prison conditions and officer conduct.
The court's decision to affirm the qualified immunity denial suggests that Crawley's allegations, if proven, would constitute violations of clearly established constitutional rights. For qualified immunity to be denied, courts must find both that a constitutional violation occurred and that the right was clearly established at the time of the alleged misconduct.
The partial reversal component of the ruling indicates that while the Ninth Circuit agreed with the district court's qualified immunity analysis, it disagreed with other aspects of the summary judgment ruling. Courts frequently issue mixed rulings in complex civil rights cases where multiple legal theories and claims are at issue.
This unpublished memorandum decision will not serve as binding precedent under Ninth Circuit Rule 36-3, but it does reflect the ongoing judicial approach to qualified immunity in the corrections context. Federal courts have increasingly rejected broad immunity claims by prison officials, particularly when fundamental constitutional rights are at stake.
The case now returns to the district court for further proceedings, where Crawley will have the opportunity to pursue his claims against the five NDOC employees without the shield of qualified immunity protection. The officers may still defend the case on the merits, arguing that no constitutional violation actually occurred.
For the Nevada Department of Corrections, the ruling represents continued scrutiny of officer conduct and policies within state facilities. Corrections departments nationwide have implemented additional training and oversight measures in response to increased judicial attention to prisoner rights and constitutional protections.
The outcome may influence how other federal courts in the Ninth Circuit approach similar qualified immunity claims involving corrections personnel. While this decision lacks precedential value, it signals the appellate court's willingness to carefully examine immunity claims and ensure that clearly established rights receive proper protection.
The case highlights the ongoing tension between officer protection through qualified immunity and prisoner rights under the Constitution. As litigation continues, both corrections officials and incarcerated individuals will be watching closely for guidance on the proper balance between these competing interests in the federal court system.