Bradford v. Hayward
4:24-cv-01293
E.D. Mo.Jul 8, 2025Background
- Aaron Bradford, a pretrial detainee at the St. Louis County Justice Center, alleges severe mistreatment during November-December 2023.
- Bradford’s claims involve unsanitary cell conditions, excessive force incidents (restraint chair and CERT team response), denial of medical care, and improper deduction of $600 from his commissary without a hearing.
- The amended complaint names thirteen defendants, all employees of the Justice Center, whom he sues in their individual capacities.
- The Court conducted initial review under 28 U.S.C. § 1915(e)(2) and found the amended complaint alleges plausible violations of the Fourteenth Amendment.
- The Court’s order allows Bradford’s claims to proceed and directs the Clerk to issue process on all defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unlawful Conditions of Confinement | Exposed to filth, feces, and contaminated water despite repeated complaints to officers | Not specified (initial review) | Sufficiently pled to proceed |
| Excessive Force (Restraint Chair & CERT) | Subjected to excessive restraints, prolonged chair use, tasing, and beating while not resisting | Not specified (initial review) | Sufficiently pled to proceed |
| Deliberate Indifference to Medical Needs | Staff ignored medical advice during restraint, failed to address serious harm from tight restraints | Not specified (initial review) | Sufficiently pled to proceed |
| Denial of Due Process (Commissary Funds) | $600 deducted without required hearing; requested but never received opportunity to contest charges | Not specified (initial review) | Sufficiently pled to proceed |
| Failure to Intervene/Protect | Officers present failed to stop apparent excessive force/abuse by other officers | Not specified (initial review) | Sufficiently pled to proceed |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility in civil cases)
- Bell v. Wolfish, 441 U.S. 520 (standard for pretrial detainee conditions of confinement)
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs standard)
- Graham v. Connor, 490 U.S. 386 (standard for excessive force claims)
- Kingsley v. Hendrickson, 576 U.S. 389 (objective reasonableness standard for pretrial detainee excessive force)
- Wolff v. McDonnell, 418 U.S. 539 (due process requirements in prison discipline)