Under the Eighth Amendment, state officials are prohibited from inflicting cruel and unusual punishment on persons convicted of crimes.  This includes the manner of treatment the prisoners receive while imprisoned and the conditions of their confinement.  The U.S. Supreme Court has stated that when a governmental entity takes a person into custody, “the Constitution imposes upon it a corresponding duty to assume some responsibility for his safety and general well being.”

In Welters v. Minnesota Department of Corrections, et al., the Minnesota Supreme Court was asked what standard to apply in a situation where a prisoner was seriously injured after he was kept in handcuffs that were too tight throughout the course of a medical procedure.  Despite his requests to have the cuffs loosened or removed during the procedure, as well as questions from medical staff about the necessity for the handcuffs, they remained on the plaintiff the entire time he was being treated and during transport.  After being injured, he sued both the corrections officers as well as the Department of Corrections (DOC) for violating his Constitutional rights.

At district court, the officers and the DOC prevailed on summary judgment after the court determined that the appropriate standard for the case was that the plaintiff had to prove the officer acted with “malicious or sadistic intent for the purpose of causing harm” when they refused to loosen his handcuffs after knowing they were overtightened.  That decision was reversed by the Minnesota Court of Appeals, which found that the plaintiff had established a “deliberate indifference” claim.  The Supreme Court sided with the Court of Appeals, finding the officers violated the plaintiff’s rights “with their cumulative conduct:”

Overtightening of his handcuffs for transport; failing to double-lock them to prevent further tightening in violation of Department of Corrections policy; ignoring his reports of numbness; refusing his requests to loosen them, knowing that he was going into a medical procedure; and unnecessarily subjecting him to overtightened handcuffs for 3 ½ hours.

The Court cited precedent that the “malicious and sadistic” standard only applies “when corrections officers are faced with a threat – whether it be from an individual inmate refusing to obey orders or a full-blown riot – and use force to maintain order and discipline.”  After finding that (based on the facts in favor of the plaintiff) the officers were not faced with any threat, as the plaintiff was placed in a cell at a Level 5 maximum security prison, the Court ruled that denying summary judgment was appropriate in this case.

Care for inmates poses many difficulties for government entities.  Employees have to be able to protect themselves from the many threats posed by housing sometimes dangerous inmates, while ensuring the safety of those inmates at the same time.  Firm President Greg Wiley has advised on both the Constitutional protections of inmates in correctional facilities as well as defending against Section 1983 claims for over a decade, and has provided training recently to law enforcement supervisors across the state.  If you, or your organization, are in need of assistance with your correctional facilities, contact Wiley Reber Law, for legal advice and defense that works.