Edwards v. Quiros, No. 19-3251 (2d Cir. 2021)
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Plaintiff, a Connecticut prisoner, filed suit under 42 U.S.C. 1983, alleging that state correctional officials violated the Eighth Amendment's prohibition against cruel and unusual punishment by denying him a meaningful opportunity to exercise for six months. In this case, the alleged denial occurred when prison officials required him to wear full restraints when exercising in the prison yard. After a jury returned a verdict for plaintiff, the district court granted the Warden's motion for judgment as a matter of law on the basis that plaintiff's personal involvement was for too short a time to support an Eighth Amendment claim.
The Second Circuit vacated the district court's entry of judgment as a matter of law, concluding that the evidence was sufficient to support the jury's findings that plaintiff was subjected to an Eighth Amendment violation. The court explained that there was sufficient evidence for the jury to find that the Warden had the requisite state of mind for the entire six-month period during which plaintiff was required to exercise in restraints when outside of his cell, not just the two weeks that the district court found; the jury's verdict was not based on "sheer surmise and conjecture," but on abundant circumstantial evidence from which a jury reasonably inferred that the Warden's actual knowledge of plaintiff's recreation status and the concomitant risk to plaintiff's health from being required to exercise in restraints; and the Warden's claims that there can be no Eighth Amendment violation are unavailing. The court also concluded that the Warden was liable for the Eighth Amendment violation, and that the Warden is not protected by qualified immunity where he knowingly violated plaintiff's clearly established right to meaningful exercise under the circumstances and lacked a sufficient justification for doing so. Accordingly, the court remanded for further proceedings.
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