Young v. Martin, No. 13-4057 (3d Cir. 2015)
Annotate this CaseYoung, a Pennsylvania prisoner with a long history of mental illness, filed suit, alleging violation of his Eighth Amendment rights by securing him in a four-point restraint chair, naked, for 14 hours, although he did not pose a threat to himself or others. Since childhood, Young has been diagnosed with various forms of mental illness, including bipolar disorder and schizo-affective disorder. Since his detention in solitary confinement, consisting of isolation for 23 hours per day and one hour of recreation time in a solitary pen on weekdays, for several years, Young’s symptoms of mental illness have intensified, including visual and auditory hallucinations, paranoid thoughts, throwing and smearing his own feces, episodes of self-harm, and suicidal impulses. The Third Circuit vacated summary judgment in favor of the defendants. Applying the use of excessive force test, analyzing the record under the criteria identified in Supreme Court precedent, and drawing all inferences in favor of Young as the non-moving party, there were genuine disputes as to material facts.
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