Welters v. Minn. Dep't of Corrections
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The Supreme Court affirmed the decision of the court of appeals reversing the district court's decision to grant summary judgment in favor of Cornelius Emily and Earnest Rhoney, Department of Corrections officers, and dismiss Plaintiff's claims of cruel and unusual punishment, holding that Plaintiff's 42 U.S.C. 1983 claim survived summary judgment.
Plaintiff, who was incarcerated in the Stillwater correctional facility, suffered serious injury in both of his wrists when Officers Emily and Rhoney improperly applied overtightened handcuffs on Plaintiff for three and one-half hours. Plaintiff brought this action seeking damages. The district court granted summary judgment, concluding that the officers did not act maliciously or sadistically. The court of appeals reversed. The Supreme Court affirmed, holding (1) the conduct of the officers should be assessed under the deliberate indifference standard applicable to conditions of confinement and medical care; and (2) qualified immunity did not bar Plaintiff's deliberate indifference claim.
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