Prisoners who claim they were assaulted by guards in violation of the Eighth Amendment are not barred from challenging such abuse in court even if they were found guilty of disciplinary charges in connection with the incident, the Sixth Circuit Court of Appeals has held. Moreover, it is erroneous for a district court to rely on a guard’s written account of the incident when videotape evidence is readily available.
In overturning a grant of summary judgment in favor of a prison guard, the Court of Appeals ruled that the guard’s alleged act of slamming a handcuffed prisoner into a wall and then to the floor was an event legally distinct from the prisoner’s alleged assault on the guard moments earlier. Prison guards who use excessive force after subduing prisoners are not immunized from court oversight as a result of disciplinary infractions against the prisoner, the Sixth Circuit wrote.
Michigan state prisoner Toran V. Peterson filed suit in federal court, claiming that a prison guard identified only as “Jones” had, without provocation, pushed up on his handcuffed arms to “slam” him into a wall, then lifted him three feet off the ground to slam him to the floor. Peterson was not seriously injured but filed a 42 U.S.C. § 1983 complaint, alleging cruel and unusual punishment in violation of the Eighth Amendment among other claims.