The United States Supreme Court has denied
an appeal in the case of two Macomb County deputies who were sued for civil rights
violations when making an arrest.
The 6th U.S. Circuit Court of Appeals, in Baynes v Cleland (Docket No. 14-2235), ruled
the defendant police officers could be held liable for handcuffing the
plaintiff, Alan Baynes, too tightly during his domestic violence arrest. In so
finding, the 6th Circuit reversed the Eastern District of Michigan, which had granted
summary judgment for the defendants based on qualified immunity.
During his arrest, the plaintiff claimed that
he told the defendants that his handcuffs were too tight. After he was released
from jail, the plaintiff was treated for injuries to his wrists and was diagnosed
with “bilateral radial sensory neuropathy from handcuffs.” He was prescribed
wrist guards to wear.
The plaintiff sued the defendants under 42
USC § 1983, asserting they violated the Fourth and Fourteenth Amendments by
using excessive force that caused him severe and permanent injuries. After the
Eastern District granted summary judgment for the defendants, the plaintiff
appealed.
The 6th Circuit reversed the Eastern
District. In so doing, the court emphasized there is plenty of case law holding
that excessively tight handcuffing is a constitutional violation. In
particular, the 6th Circuit cited the U.S. Supreme Court’s ruling in Hope v Pelzer, 536 US 730 (2002), for the proposition
that officials must be on notice that their alleged conduct was
unconstitutional.
“In Hope, the Supreme
Court established that, for purposes of qualified immunity, the precise factual
scenario need not have been found unconstitutional for it to be sufficiently
clear to a reasonable official that his actions violate a constitutional right
— that is, for the right to be ‘clearly established,’” the 6th Circuit said. “In
fact, the Supreme Court determined that government officials can still be on
notice that their conduct violates established law even in novel factual
circumstances.”
The 6th Circuit further noted the court has
consistently held that excessively forceful handcuffing violates the Fourth
Amendment, and that its rulings sufficiently put a reasonable officer on notice
that “unduly tight handcuffing” is a constitutional violation. Therefore, “the
law is sufficiently clear for the purpose of the clearly established prong of the
qualified immunity analysis,” the 6th Circuit said.
Applying these principles this case, the 6th
Circuit said that, while the Eastern District recognized there is a general
right to be free from unduly tight handcuffing, the district court proceeded to
mistakenly find that the right was not clearly established in this case because
a reasonable officer would not have known that he was violating the plaintiff’s
Fourth Amendment rights.
According to the 6th Circuit, the Eastern District relied too heavily on the unpublished opinion in Fettes v Hendershot, 375 F App’x 528 (6th Cir, 2010). “It was at this point that the district court erred,” the 6th Circuit said. “The factual nuances the district court noted to distinguish [the plaintiff’s] case from this Court’s extensive precedent on unduly tight handcuffing amount to precisely the kind of rigidity the Supreme Court foreclosed in Hope.”
The defendants thereafter appealed the 6th Circuit's decision to the U.S. Supreme Court, which denied the petition for writ of certiorari on March 7, 2016 (Docket No. 15-852).
According to the 6th Circuit, the Eastern District relied too heavily on the unpublished opinion in Fettes v Hendershot, 375 F App’x 528 (6th Cir, 2010). “It was at this point that the district court erred,” the 6th Circuit said. “The factual nuances the district court noted to distinguish [the plaintiff’s] case from this Court’s extensive precedent on unduly tight handcuffing amount to precisely the kind of rigidity the Supreme Court foreclosed in Hope.”
The defendants thereafter appealed the 6th Circuit's decision to the U.S. Supreme Court, which denied the petition for writ of certiorari on March 7, 2016 (Docket No. 15-852).
Labels: appeal, appeals, fourteenth Amendment, fourth amendment, Michigan, Michigan Appeal, Michigan Appeals, qualified immunity, U.S. 6th Circuit Court of Appeals, United State Supreme Court
