Hill v. Crum, No. 12-6705 (4th Cir. 2013)
Annotate this CasePlaintiff filed suit against a correctional officer alleging that he used excessive force against plaintiff. Without provocation, the officer assaulted plaintiff for about two minutes before the officer moved plaintiff to a holding cell, knocking his head against a gate on the way out. The prison staff then kept plaintiff in ambulatory restraints for seventeen hours following the assault. On appeal, the officer appealed the district court's denial of his Rule 50(b) motion for judgment as a matter of law. Because no extraordinary circumstances were applicable to plaintiff's injuries and he suffered no more than de minimis injury, he could not, at the time the assault took place, state a claim upon which relief could be granted under the Eighth Amendment. Therefore, the right he sought to avail himself of was not clearly established in the Fourth Circuit at the time of the alleged suit and the officer was entitled to qualified immunity. Accordingly, the court reversed and remanded.
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