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Media Alerts - Young v. Martin et al. - Third Circuit
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September 11, 2015
  Young v. Martin et al. - Third Circuit
Headline: District Court erred in granting summary judgment where it failed to apply the excessive force test to mentally ill prisoner's claim of an Eighth Amendment violation against prison officials who strapped him in a restraint chair for fourteen hours.

Area of Law: Constitutional Law; Eighth Amendment

Issue(s) Presented: Whether the district court erred by granting summary judgment in favor of the Defendants by concluding that they did not violate Young's Eighth Amendment rights when they strapped him in a restraint chair naked for fourteen hours even though he posed no imminent threat of bodily harm to himself or others.

Brief Summary: A prisoner in a Pennsylvania correctional facility was secured in a four-point restraint chair naked for fourteen hours after an incident where he left his cell, which had been mistakenly left open. This prisoner had a history of mental illness, which had been exacerbated during years of solitary confinement.

The Third Circuit found that the prisoner's Eighth Amendment claims against the prison officials regarding the use of the restraint chair should be analyzed under the excessive force test as articulated by the United States Supreme Court. Applying that test, and drawing all reasonable inferences in favor of Young, the Third Circuit noted that reasonable minds could differ as to whether Young was already subdued when restrained, whether the situation leading up to the restraint constituted an emergency situation, and whether he was subjected to substantial harm and pain without penological justification.

Because genuine disputes of material fact existed as to whether Defendants' use of the restraint chair constituted excessive force in violation of the Eighth Amendment, the Third Circuit held that the district court erred in granting summary judgment to Defendants.

Extended Summary: Leonard G. Young, Jr., is a Pennsylvania prisoner with a long history of mental illness, including bipolar disorder and schizophrenia dating back to his childhood. For over six years, he has been held in solitary confinement in either restrictive housing or mental health units. Since his detention in solitary confinement, his symptoms have intensified, including episodes of hallucinations, paranoia, self-harm, and suicide attempts.

On September 20, 2009, Young's cell door was mistakenly unlocked and left open. Young exited, climbed several flights of stairs, and ended up on an internal roof in the law library. After a few minutes of yelling down his protests regarding prisoners' rights, Young followed correctional officers' (COs) orders to come down. He further complied with COs as they handcuffed him, but when Young then refused to walk by laying on the ground, his ankles were shackled and the COs carried him down another staircase.

Young was then placed face down on the ground and further restrained by four COs. Young remained motionless and did not struggle. Still, he was placed in a spit mask, his clothes were cut off, and a strip search was performed. After placement in a restraint chair was authorized by Defendants "to prevent [Young] from harming himself or staff," he was strapped into the chair naked with a smock placed over his lap. He did not physically resist, but he did complain that the restraints were too tight and cried out in pain while being strapped into the chair.

At 8:46 p.m., Young was wheeled into an air-conditioned cell and left naked except for the smock. A nurse evaluated him and found the restraints were too tight. He fell asleep, awoke at 5:20 a.m., and was cooperative in agreeing to see a psychiatrist and take medication. Later that morning, still in the chair, Young became agitated and stated he would "act out" when released. He was released at 10:30 a.m., totaling nearly fourteen hours in the chair. This exceeded the two-hour maximum recommended by the chair's manufacturer and the eight-hour maximum, absent special authorization, permitted by the prison's regulations. Defendants conceded that there was no evidence on record that anyone authorized a restraint exceeding the eight-hour maximum. Moreover, because of the air-conditioning blowing on his naked body during this period, Young's legs become numb and he could not walk upon his release and had to be wheeled back to his restrictive housing unit.

Young sued Defendants, claiming his placement in the chair constituted excessive force in violation of the Eighth Amendment. The district court granted Defendants' motion for summary judgment, noting that Defendants acted professionally and did not use excessive force because Young was agitated, violence-prone, and stated he would act out upon his release from the chair. Young appealed. The Third Circuit first had to determine whether to analyze Young's Eighth Amendment claim under the excessive force test or the condition of confinement test. The Eighth Amendment prohibits the infliction of cruel and unusual punishment. This prohibition bars prison officials from using excessive force against inmates and it imposes an affirmative duty on prison officials to provide humane conditions of confinement.

The Third Circuit examined a United States Supreme Court case that addressed whether the use of mechanical restraints constituted cruel and unusual punishment. The Supreme Court held that because the prisoner was subdued leading up to his restraint and no longer posed a safety risk, subjecting him to substantial risk of physical harm and unnecessary pain, discomfort, and humiliation in the way described served no penological justification. This was "unnecessary and wanton" and constituted cruel and unusual punishment under the Eighth Amendment. Although Defendants argued that the Supreme Court applied the conditions of confinement test in the leg iron case, the Third Circuit found this to be, in fact, an application of the excessive force analysis. Therefore, the Third Circuit concluded that Young's claims should be analyzed under the excessive force test as articulated by the Supreme Court.

Applying the excessive force test to its review of the record, the Third Circuit found that the district court failed to draw all reasonable inferences in Young's favor, and that there were genuine disputes of material fact regarding whether Defendants' use of the restraint chair violated the Eighth Amendment. First, given that Young was not violent or combative leading up to the restraint, the Court found that reasonable minds could differ as to whether Young posed a risk to himself or others. Second, because Young's cell door was left open, his exit did not amount to a prison break. Also, he complied with COs' orders following the initial roof incident, so a reasonable jury could find that the events of that day did not amount to an emergency situation. Lastly, due to Young's restraints being too tight and the air-conditioning blowing on his naked body during his extended period in the chair, the Court reasoned that Young was entitled to have a jury determine whether he was subjected to a substantial risk of physical harm without penological justification. The Third Circuit, therefore, vacated the grant of summary judgment in favor of Defendants and remanded the case for further proceedings.

The full opinion can be found at http://www2.ca3.uscourts.gov/opinarch/134057p.pdf

Panel: McKee, Chief Judge; Greenway, Jr. and Krause, Circuit Judges

Argument Date: October 29, 2014

Date of Issued Opinion: September 8, 2015

Docket Number: No. 13-4057

Decided: Vacated and remanded

Case Alert Author: Elizabeth C. Dolce

Counsel: Elizabeth F. Collura, Esquire, and Roert J. Ridge, Esquire, Counsel for Appellant; Sandra A. Kozlowski, Esquire, and Kemal A. Mericli, Esquire, Office of Attorney General of Pennsylvania, Counsel for Appellees

Author of Opinion: Circuit Judge Krause

Circuit: Third Circuit

Case Alert Circuit Supervisor: Professor Mary E. Levy

    Posted By: Susan DeJarnatt @ 09/11/2015 04:17 PM     3rd Circuit  

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