Harvell v. Rigney, et al.

9th Cir. No. 25-719

Mr. Harvell was incarcerated at a Nevada state prison when correctional officers entered his cell and beat while he was handcuffed. Mr. Harvell filed Eighth Amendment excessive force claims against two officers who beat him and a third who failed to intervene.

The district court denied the officers' motion for summary judgment on qualified immunity grounds, and they appealed. The Ninth Circuit affirmed, holding that beating a person who is handcuffed and subdued violates a clearly established constitutional right. The Court also rejected the officers' novel argument that prison grievance findings should be treated as binding administrative determinations, holding that federal courts review constitutional claims under their own standards, not those of the internal prison grievance process.