Jackson v. Gutzmer

Plaintiff filed suit against correctional officers and medical staff under 42 U.S.C. 1983, after he spent three and a half hours on a restraint board. The district court dismissed all claims except an Eighth Amendment excessive force claim against Lieutenant Jeff Gutzmer, who authorized use of the restraint board. The Eighth Circuit held that the district court erred as a matter of law when it denied qualified immunity to Gutzmer. The court held that Gutzmer was entitled to qualified immunity if the totality of the circumstances justified use of the restraint board even if Gutzmer erred in believing plaintiff was self-injurious when placed on the board. In this case, plaintiff violated rules for obtaining medical assistance, falsely claimed a medical emergency, and seriously disrupted ACU operations; discipline was warranted after nurses reported that plaintiff had contrived a medical emergency and could safely be placed on the restraint board; and employing the restraint in accordance with the safety precautions required by prison policy was needed to preserve internal order and discipline and to maintain institutional security. View "Jackson v. Gutzmer" on Justia Law