Fairchild, et al v. Coryell Cty, et al, No. 20-50237 (5th Cir. 2022)
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While awaiting trial a woman began tapping her hairbrush on the cell door. One of the two primary jailers asked the woman to turn around to be handcuffed. When she did not obey, the jailer used pepper spray which caused her to retreat toward the far wall. While the woman remained at the back of her cell facing away from the jailers, one of the jailers sprayed the woman with pepper spray three more times.
The struggle resulted in the woman lying flat on her stomach with her hands handcuffed behind her back, and one of the jailers, who weighed 230 pounds, sitting atop of her with his knee on her back. The other jailer, who weighed 390 pounds, pressed his forearm against her neck for over two minutes. The jailers rolled the woman over to find her unresponsive and she was declared dead. The woman’s parents filed a section 1983 suit against the county and the jailers. At summary judgment, the district court held that the jailers’ use of force was reasonable.
The Fifth Circuit reversed, explaining that a jury could conclude that the jailers used excessive force. Further, the jailers’ continuing to apply that force for more than two minutes after the woman was subdued would violate clearly established law. The court explained any reasonable officer would see that the woman represented a low threat at the moment when the jailer threw her to the floor and applied continuous force. Further, the woman did not actively resist at these critical stages of the encounter. Finally, the amount of force was not proportional to the need for force.
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