Summary
This Second Circuit opinion determines the appropriate constitutional standard for excessive force claims brought by an individual detained after a parole violation. The court held that the Eighth Amendment, rather than the Fourteenth Amendment, governs such claims when the plaintiff has received a final adjudication and formal revocation of parole, rendering them legally indistinguishable from a convicted prisoner. The district court's denial of qualified immunity was vacated and remanded for analysis under the Eighth Amendment standard.
Topics
Practice areas
Questions Presented
- Whether the Second Circuit had interlocutory appellate jurisdiction to review the denial of qualified immunity on summary judgment.
- Whether the Eighth or Fourteenth Amendment governs excessive-force and related failure-to-intervene claims brought by a parole violator whose parole had been finally adjudicated and revoked before the challenged use of force.
- Whether the district court applied the wrong constitutional standard in analyzing qualified immunity.
Holdings
- The court had jurisdiction under the collateral-order doctrine to review the denial of qualified immunity to the extent the appeal presented legal questions, including the governing constitutional standard.
- The Eighth Amendment, rather than the Fourteenth Amendment, governs an excessive-force claim brought by a parole violator who received a final adjudication and had parole formally revoked before the challenged use of force.
- The district court must analyze defendants' qualified-immunity defense under the Eighth Amendment standard in the first instance.
Key quotations
“Whatever the appropriate standard for alleged parole violators, the Eighth Amendment governs excessive force claims where the plaintiff received a final adjudication prior to the challenged use of force, and thus became an adjudicated parole violator.” (2-3)
“Having entered a guilty plea and having had his parole formally revoked, Farrington was materially identical to a convicted prisoner at the time of the relevant incident.” (14-15)
“We vacate and remand for the district court to do so in the first instance.” (15-16)
Factual background
Farrington was arrested in March 2020 and detained at Albany County Correctional Facility for an alleged parole violation. He participated in a final parole-revocation hearing on April 14, 2020, pled guilty to violations, and had his parole formally revoked before correctional officers used or observed force during a May 2020 altercation. The district court applied the Fourteenth Amendment because it believed the record did not establish whether Farrington's parole violation had been adjudicated before the incident.
Procedural history
Farrington sued correctional officers in the Northern District of New York over force used at Albany County Correctional Facility. The district court granted summary judgment in part, denied it in part on the excessive-force claims, applied the Fourteenth Amendment standard, and denied qualified immunity. The Second Circuit exercised collateral-order jurisdiction to review the legal question concerning the governing constitutional standard, vacated the order, and remanded.
Remand instructions
Vacate the district court's order and remand for the district court to analyze defendants' qualified-immunity defense under the Eighth Amendment standard in the first instance.