Jerome Hayes v. Sergeant Bennett and Lieutenant Lurry

Summary

The United States District Court for the Northern District of Florida partially accepts and partially rejects a magistrate judge’s report and recommendation in a prisoner civil-rights action. The court dismisses the deliberate-indifference and compensatory-damages claims, grants summary judgment for Defendant Lurry on the excessive-force claim, and denies summary judgment for Defendant Bennett because material factual disputes remain regarding the force used during a cell extraction. The court schedules a telephonic status conference to discuss trial dates.

Holdings

1. Hayes's allegations, taken as true and construed with reasonable inferences in his favor, did not state a claim for deliberate indifference.
2. Hayes did not allege a plausible de minimis injury sufficient to maintain his claim for compensatory damages.
3. Summary judgment was denied as to Bennett because genuine disputes of material fact remained concerning how much force Bennett used, whether the force exceeded what was necessary to gain control of Hayes, and whether the force caused Hayes's facial injuries.
4. Lurry was entitled to summary judgment on the excessive-force claim.
5. The court could not determine as a matter of law that Bennett was entitled to qualified immunity because the disputed factual issues concerning the force used had to be resolved before the immunity question could be decided.
6. The court declined to limit Hayes's excessive-force claim to an injury to his left eye where the record showed facial injury and Hayes had difficulty distinguishing left from right.

Questions Presented

1. Whether Hayes plausibly stated claims for deliberate indifference and compensatory damages.
2. Whether genuine disputes of material fact precluded summary judgment on Hayes's excessive-force claim against Bennett.
3. Whether Lurry was entitled to summary judgment on the excessive-force claim because he ordered a use of force but did not personally use excessive force or have an opportunity to intervene.
4. Whether Bennett was entitled to qualified immunity at the summary-judgment stage despite disputed facts concerning the amount and circumstances of force used.

Disposition

other