Jackson v. Gutzmer, No. 16-2184 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit against correctional officers and medical staff under 42 U.S.C. 1983, after he spent three and a half hours on a restraint board. The district court dismissed all claims except an Eighth Amendment excessive force claim against Lieutenant Jeff Gutzmer, who authorized use of the restraint board. The Eighth Circuit held that the district court erred as a matter of law when it denied qualified immunity to Gutzmer. The court held that Gutzmer was entitled to qualified immunity if the totality of the circumstances justified use of the restraint board even if Gutzmer erred in believing plaintiff was self-injurious when placed on the board. In this case, plaintiff violated rules for obtaining medical assistance, falsely claimed a medical emergency, and seriously disrupted ACU operations; discipline was warranted after nurses reported that plaintiff had contrived a medical emergency and could safely be placed on the restraint board; and employing the restraint in accordance with the safety precautions required by prison policy was needed to preserve internal order and discipline and to maintain institutional security.
Court Description: Loken, Author, with Murphy and Benton, Circuit Judges] Prisoner case - Prisoner civil rights. In action alleging defendant Gutzmer violated plaintiff's civil rights by ordering him placed on a restraint board for three-and-one-half hours, Gutzmer is entitled to qualified immunity on plaintiff's excessive force claim if the totality of the circumstances justified use of the restraint board even if Gutzmer erred in believing plaintiff was self-injurious when placed on the board; the undisputed facts established that plaintiff was causing a disturbance in his cell in order to bypass prison rules for obtaining medical attention and that his behavior was seriously disrupting unit operations; this conduct was a rule violation warranting discipline, and use of the restraint board under the conditions present and with the safety precautions undertaken did not establish an Eighth Amendment excessive force violation; the district court erred in denying Gutzman's motion for summary judgment based on qualified immunity.
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