Amos v. Jefferson, 19-40286

Background

Plaintiff Calvin Amos, an Arkansas inmate, was subject to two brief chemical-agent sprays by Corporal Denise Jefferson after he acted belligerent and noncompliant during suicide-watch/security procedures; the events were recorded on video.
Video shows Amos resisting orders, taunting Jefferson, being partially uncuffed and guided while officers re-applied cuffs, turning his head toward Jefferson, and later rising in a holding cell after being told to remain seated. Each spray lasted about one to two seconds.
After each spray nurses evaluated Amos, measured oxygen (found it normal), advised on decontamination using running water in his cell, and cleared him to return to his cell.
Amos alleged Eighth Amendment excessive-force and deliberate-indifference to medical needs claims, plus conspiracy and supervisory-failure claims; he also sought appointed counsel.
The magistrate judge granted summary judgment for all defendants (in part on qualified immunity); Amos appealed. The Fifth Circuit affirmed, giving substantial weight to the video and finding no disputed material facts that would preclude judgment for defendants.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force (Jefferson) — Eighth Amendment	Jefferson sprayed Amos while he was complying or not within range; spray was unnecessary and caused injury; Jefferson knew he had an allergy.	Amos was repeatedly combative and defiant; Jefferson warned him and used brief sprays to restore order and compel compliance.	Summary judgment for Jefferson; qualified immunity applies because brief sprays under these circumstances were not clearly unlawful.
Deliberate indifference to medical needs (Willis, Story, Arnold)	Nurses refused further treatment, denied use of eye wash, ignored lack of running water, delayed care causing ongoing injuries.	Nurses evaluated Amos after sprays, checked oxygen, advised decontamination with running water in his cell, and cleared him; no denial or impermissible delay.	Summary judgment for nurses; no deliberate indifference as a matter of law—treatment (though imperfect) was provided.
Conspiracy, supervisory failure, falsification claims	Staff conspired to deny care; supervisors failed to protect; documents falsified.	Insufficient evidence; plaintiff failed to brief or oppose these rulings.	Claims abandoned or unsupported; summary judgment affirmed for lack of briefing/evidence.
Appointment of counsel	Amos asserted inability to litigate without counsel.	Appointment not required absent exceptional circumstances; case not complex and largely relies on video.	Denied; no exceptional circumstances and no abuse of discretion.

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate-indifference standard for medical care)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference requires actual knowledge of substantial risk)
Pearson v. Callahan, 555 U.S. 223 (qualified-immunity two-prong framework)
Hudson v. McMillian, 503 U.S. 1 (use-of-force context; deference to prison officials to maintain order)
Scott v. Harris, 550 U.S. 372 (video evidence may discredit plaintiff’s account at summary judgment)
Tolan v. Cotton, 572 U.S. 650 (summary-judgment review must construe facts in favor of nonmovant)
Mullenix v. Luna, 577 U.S. 7 (clarifies clearly established-law inquiry for qualified immunity)
Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established rights must be beyond debate)
Baldwin v. Stalder, 137 F.3d 836 (5th Cir. upholding brief use of chemical agents to maintain discipline)
Newman v. Guedry, 703 F.3d 757 (Fifth Circuit accords substantial weight to on-scene video evidence)