Ussery v. Mansfield, No. 14-7096 (4th Cir. 2015)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1982, alleging that correctional officers used excessive force when they forcibly extracted him from his prison cell. The officers appealed the district court's denial of their motion for summary judgment on the basis of qualified immunity. The parties agree that the law clearly established at the time of the extraction governs the entitlement to qualified immunity here. In Norman v. Taylor, the court held that absent the most extraordinary circumstances, a plaintiff cannot prevail on an Eighth Amendment excessive force claim if his injury is de minimis. Applying Norman, the court concluded that many of plaintiff's injuries could have an enduring impact on health and well-being and were not de minimis. Accordingly, the court affirmed the judgment of the district court.
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