Stearns v. Inmate Services Corp., No. 18-3707 (8th Cir. 2020)
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Plaintiff filed a 42 U.S.C. 1983 action against ISC, alleging that ISC transported plaintiff, a pretrial detainee subject to extradition, for eight continuous days across twelve states, with only momentary breaks for bathroom use.
The Eighth Circuit held that ISC is not entitled to summary judgment on the current record based on the standards applicable to pretrial detainees under Bell v. Wolfish, 441 U.S. 520, 535 n.16 (1979). In this case, prior to being found guilty of any offense, plaintiff was subjected to painful, unsanitary, and severe conditions and restraints for over one week. Viewing the totality of the circumstances, the court held that the conditions of plaintiff's confinement were far from de minimis and a jury could reasonably conclude that, on this record, the conditions were arbitrary or excessive when compared to the government's perceived goal of securely transporting plaintiff to his destination.
Court Description: [Melloy, Author, with Kelly and Stras, Circuit Judges] Prisoner case - Prisoner civil rights. In action alleging defendant violated plaintiff's civil rights as a pretrial detainee by subjecting him to an eight-day, cross-country extradition journey in which he was forced to sit shackled, with only momentary breaks for bathroom use, defendant was not entitled to summary judgment on the current record; because this case is based on a pretrial detainee's right to be free from punishment, it is governed by the objective standard of Bell v. Wolfish, 441 U.S.C. 520 (1979); the conditions of plaintiff's confinement were far from de minimis and a jury could reasonably conclude that, on this record, the conditions were arbitrary or excessive when compared with the government's perceived goal of securely transporting plaintiff from Colorado to Mississippi. Judge Stras, concurring in the judgment.
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