Rheuark v. Shaw
This federal civil rights case addresses constitutional violations stemming from extensive delays in preparing trial transcripts for indigent criminal appellants in Dallas County, Texas. Plaintiffs John Doescher, Robert Allen Jordan, and Jack Rheuark alleged that delays of nine to twenty-three months violated their due process rights under 42 U.S.C. § 1983. The court found these delays unconstitutional, awarding nominal damages to Doescher and Rheuark, and $3,000 in actual damages to Jordan. While denying injunctive relief and punitive damages, the court determined that individual defendants—Judge Metcalf, Dallas County Commissioners, and court reporter Paul Bastas—were immune from personal damage liability due to judicial, legislative, and qualified immunities, respectively. However, Dallas County was held liable for damages and attorneys' fees due to an official policy and custom of inadequately funding court reporters that directly caused the unconstitutional delays, and attorneys' fees were awarded to the plaintiffs against the individual defendants in their official capacities and Dallas County.