Antonio Smith v. John Kind, 140 F.4th 359

Antonio Smith, an inmate at Green Bay Correctional Institution, engaged in a 50-day hunger strike protesting prison conditions.
Correctional officers repeatedly extracted Smith from his cell for wellness checks; on the fourth day, Captain Van Lanen shifted to using pepper spray despite Smith having a known medical contraindication (asthma).
After being pepper sprayed, Smith was placed naked in a cold control cell without access to clothing or bedding for 23 hours, during which outside temperatures ranged from 25 to 57°F.
Smith brought claims under 42 U.S.C. § 1983 alleging Eighth Amendment violations (excessive force and unconstitutional conditions of confinement) against multiple correctional officials.
The district court granted summary judgment to all defendants, holding there was no constitutional violation; Smith appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Use of pepper spray (excessive force)	Use was wanton, not needed, and medically dangerous given Smith’s condition.	Use justified for compliance and inmate’s past violent history.	Qualified immunity applies; no clearly established right under these exact facts.
Conditions of confinement (cold cell)	Deliberate and extreme deprivation of warmth/clothing violated the Eighth Amendment.	Conditions not unconstitutionally severe; actions taken in good faith.	Could violate Eighth Amendment, but qualified immunity applies—no clearly established law on these precise facts.
Escort after pepper spray	Officers used excessive physical force (chokeholds, wrist bending) during the escort.	Officers acted appropriately; video shows no malice or improper use of force.	No genuine dispute of material fact; video evidence precludes claim.

Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment excessive force standard in prisons)
Wilson v. Seiter, 501 U.S. 294 (objective/subjective standards for Eighth Amendment claims)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard)
Whitley v. Albers, 475 U.S. 312 (malicious and sadistic use of force standard)
Hope v. Pelzer, 536 U.S. 730 (qualified immunity—when a violation is obvious, precise case law not needed)
Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity: clearly established rights)
Dixon v. Godinez, 114 F.3d 640 (inmates’ right to protection from extreme cold)
Henderson v. DeRobertis, 940 F.2d 1055 (qualified immunity and cold cell exposure)
Lewis v. Lane, 816 F.2d 1165 (cold cell Eighth Amendment standards)
Soto v. Dickey, 744 F.2d 1260 (use of chemical agents on inmates and qualified immunity)