Ryan v. Armstrong, No. 16-1341 (8th Cir. 2017)Annotate this Case
After Jerome Harrell died while in custody at the county jail, Harrell's estate filed suit against the county and various correctional officers under 42 U.S.C. 1983, alleging violations of Harrell's constitutional rights as well as other claims. The district court granted summary judgment for defendants. The court concluded that genuine issues of fact remain on the question of whether defendants Armstrong and Culloton were deliberately indifferent to Harrell's serious medical needs when they allowed him to scream, howl, and bang against his cell door for eight hours without attempting to talk to him or seek medical intervention. Therefore, the district court erred by granting summary judgment to Armstrong and Culloton on the ground that they were entitled to qualified immunity, and the court reversed as to this issue. The court concluded that defendants were entitled to qualified immunity on the trustee's excessive force claim where, among other things, Harrell was actively resisting the extraction procedure by ignoring directives to lie down on his bunk and resisting defendants' efforts to subdue him once they entered his cell, and defendants' testimony about the degree of Harrell's resistance was corroborated. Under the totality of these circumstances, none of the defendants' actions, either singly or in combination, amounted to an objectively unreasonable application of force. Therefore, the court affirmed as to the excessive force claim. Because the court was remanding some of the federal claims, the court also vacated the dismissal of the state law claims and remanded.