Jacobs v. Cumberland County, No. 19-3269 (3d Cir. 2021)
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Jacobs, in Cumberland County Jail awaiting trial for a weapons charge, got into a fight with Hanby, another inmate. Less than 30 seconds after the fight ended, corrections officers entered the dorm and identified Hanby as one of the fighters. The officers removed Hanby and took him to the medical unit. About 15 minutes later, officers returned for Jacobs. In a suit under 42 U.S.C. 1983, Jacobs claims that as the officers removed him from his cell, they violated his Fourteenth Amendment right to be free from excessive force amounting to punishment.
The officers moved for summary judgment on the ground of qualified immunity. After reviewing the record, including a security video, the district court denied the motion, finding that a reasonable jury could find that the officers used gratuitous force and that any reasonable officer would have known that such force was unlawful. The Third Circuit affirmed, first noting the objective standard used in analyzing claims by pretrial detainees. The Supreme Court has made clear that officers may not expose inmates to gratuitous force divorced from any legitimate penological purpose. Here, reasonable jurors could conclude that the officers were not facing a disturbance or any threat to jail security. When they returned for Jacobs they found the inmates orderly and compliant. Jacobs posed no threat throughout the encounter.
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