Case Explained: Thomas Riles v. Carroll County, Arkansas, an Arkansas Municipality; Anthony Scotti, formerly known as Andrew Scotti Officer Laralyn Koster

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-05 The eighth-circuit dismissed Officer Laralyn Koster’s interlocutory appeal challenging the district court’s denial of her motion for summary judgment based on qualified immunity. The court held that it lacked jurisdiction because the appeal required re-weighing evidence and making credibility determinations regarding whether Koster knew Riles had a serious medical need, was aware he vomited in his cell, and laughed at him. Under the collateral order doctrine, the appellate court’s review is limited to abstract issues of law and must accept the district court’s version of the facts unless they are “blatantly contradicted by the record.” Because the district court’s factual findings were supported by Riles’s testimony and other evidence in the record, Koster’s arguments that she did not know of the medical need or that the right was not clearly established exceeded the scope of permissible interlocutory review. Consequently, the appeal is dismissed without reaching the merits of the qualified immunity defense, leaving the district court’s denial of summary judgment intact for further proceedings. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.