Ward v. Smith, No. 15-2583 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against two correctional officers, Smith and Merriett, under 42 U.S.C. 1983. Plaintiff alleged that the officers used excessive force when they administered pepper spray to gain plaintiff's compliance with orders to submit to wrist restraints. The district court granted summary judgment for the officers. The court concluded that the evidence does not clearly refute the district court's finding that Officer Smith did not intentionally administer pepper spray to plaintiff's genitals; the district court did not clearly err in deciding the decision to use pepper spray was not pretext to punish plaintiff and instead the use of force was in direct response to plaintiff's refusal to comply with the orders to submit to restraints in preparation to be removed from and returned to his cell; and plaintiff's claim of intentional infliction of emotion distress was rejected where plaintiff has failed to show that Officer Smith's sole intent in acting was to cause emotional distress.
Court Description: Shepherd, Author, with Melloy and Colloton, Circuit Judges] Prisoner case - Prisoner civil rights. Defendants' judgment on claim they used excessive force when they used pepper spray to gain plaintiff's compliance with orders to submit to wrist restraints affirmed; plaintiff had been lawfully ordered to submit to the restraints and refused to comply and the force used was not disproportionate to security concerns and was not, therefore, cruel or unusual; the evidence does not clearly refute the district court's finding that the defendant guard was attempting to spray plaintiff's face and not his genitals during a fourth administration of the spray; district court did not err in determining plaintiff had failed to prove his claim of intentional infliction of emotional distress under Missouri law.
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