Evans v. Smith
8th Cir. No. 24-1882
Mr. Evans was left in leg restraints for 15 hours after being returned to his cell — with no penological justification whatsoever. The officers who refused to remove the restraints had a history of threatening Mr. Evans. He spent the better part of those 15 hours standing at his cell door calling out for help. Other officers heard him and did nothing. Because the leg restraints made it impossible to remove his clothes normally, Mr. Evans had to cut them off with a razor just to shower.
When Mr. Evans sued for excessive force, the officers claimed they were entitled to qualified immunity, which the lower court denied. The officers appealed the denial of qualified immunity, and further asserted that refusing to remove restraints isn't really "using force" at all. The Eighth Circuit affirmed the district court’s denial of qualified immunity and found that deliberately leaving someone in restraints with no justification, causing real pain and suffering, is a use of force under the Eighth Amendment.
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