Jaquan M. Davis v. Aren Messer, et al.

Summary

The United States District Court for the Western District of North Carolina granted summary judgment to detention-center defendants in a pretrial detainee’s 42 U.S.C. § 1983 action. The court held that the force used to remove Jaquan M. Davis from his cell and place him in a restraint chair was objectively reasonable and that the evidence did not establish deliberate indifference to a serious medical need. The court also concluded that the defendants were entitled to qualified immunity and dismissed the action with prejudice.

Holdings

1. The defendants did not use objectively unreasonable force in taking Davis to the floor, striking him once, and pressing his head to the floor while securing him after repeated refusals to comply and physical resistance.
2. Defendants were entitled to summary judgment because Davis failed to forecast evidence that he had a sufficiently serious injury known or obvious to defendants or that defendants acted with deliberate indifference to it.
3. Defendants were entitled to qualified immunity because Davis failed to show that any defendant violated a constitutional right.
4. Summary judgment was proper because Davis relied on an unverified complaint and response and failed to present admissible evidence establishing a genuine dispute of material fact.

Questions Presented

1. Whether defendants used excessive force against Davis in violation of the Fourteenth Amendment.
2. Whether defendants were deliberately indifferent to Davis's serious medical need in violation of the Fourteenth Amendment.
3. Whether defendants were entitled to qualified immunity.
4. Whether defendants were entitled to summary judgment because Davis failed to present admissible evidence establishing a genuine dispute of material fact.

Disposition

dismissed