Prison officials may generally rely on the defense of qualified immunity to protect them from liability for civil damages.

Under this heightened pleading standard, actions against governmental officials must be pleaded: with sufficient precision to put defendants on notice of the nature of the claim and enable them to prepare a response and, where appropriate, a summary judgment motion on qualified immunity grounds.

A defendant is not entitled to qualified immunity if:(1) her conduct violated a constitutional right clearly established before the conduct occurred;(2) she knew or should have known of the clearly established right when the conduct occurred; and (3) she knew or should have known that her conduct violated the plaintiff's right.

The other courts of appeals have uniformly embraced a heightened pleading standard in qualified immunity cases.

The case must be pled with sufficient detail to put the defendants on notice of the nature of the claim so that they may adequately respond. Id

—trial court has no discretion to allow use of evidence of conviction for impeachment when pardon states that it was based on rehabilitation

A prisoner may sue a state official in his individual capacity under 42 USC § 1983 when the official acts under color of state law to deprive the inmate of rights guaranteed to him by the Constitution or by federal laws.

[CITATION] Moore's Federal Rules Pamphlet