Staples v. Gerry, No. 18-1727 (1st Cir. 2019)
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The First Circuit affirmed the judgment of the district court granting summary judgment for two prison officers on an inmate's claims under 42 U.S.C. 1983 alleging violations of his federal constitutional rights, holding that the officers were entitled to qualified immunity.
In his complaint, the inmate alleged (1) one of the officers pushed him against a pillar, allegedly causing him to hit his head on it, in violation of the Eighth Amendment; and (2) the other officer sprayed pepper spray into his cell, in violation of both the First Amendment and the Eighth Amendment. The district court granted Defendants' motion for summary judgment on qualified immunity grounds. The First Circuit affirmed, holding that no genuine dispute of material fact existed as to whether the officers violated either the First or the Eighth Amendment.
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