Cecil Edwards, Jr. v. Karl Byrd, 750 F.3d 728

Pretrial detainees Edwards, Merrick, Smith, Perry, and Manning were held in Faulkner County Detention Center Pod B during Oct 24, 2010 incident.
Disturbance in Pods A and C caused water pooling; plaintiffs remained in Pod B and attempted to block water by placing a blanket at their pod door.
Guards used force to enter Pod B after detaining other detainees; a towel wedged under the door impeded access.
Flash-bang grenades were deployed; Edwards was burned; several plaintiffs were punched, kicked, or shot with bean-bag rounds; detainees were left in standing water.
Plaintiffs, pretrial detainees, alleged excessive-force and failure-to-protect under 42 U.S.C. § 1983; district court denied some claims and granted others on qualified immunity grounds.
Court reviews the denial of summary judgment on qualified immunity for Sheriff Byrd (individually) and guards on interlocutory appeal under collateral order doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether guards’ use of force against pretrial detainees violated their rights	Byrd/guards used force to inflict harm rather than restore order	Force used was to regain control during disturbance	Qualified immunity denied for guards; issue preserved for appeal
Whether failure to intervene to protect detainees from excessive force violated due-process	Guards knew excessive force was used and did not intervene	No individual Byrd involvement; no intervention issue for Byrd	Failure-to-protect claim denied for Byrd; Byrd entitled to qualified immunity

Putnam v. Gerloff, 639 F.2d 415 (8th Cir. 1981) (due-process rights of pretrial detainees; risk and intervention standard)
Graham v. Connor, 490 U.S. 386 (1989) (reasonableness in use of force; objective inquiry for excessive force)
Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainee protections; punishment and due process)
Scott v. Harris, 550 U.S. 372 (2007) (video evidence may be conclusive on summary judgment when it contradicts non-conclusive account)
White v. Smith, 696 F.3d 740 (8th Cir. 2012) (limits on appellate review of district court’s factual findings in qualified-immunity context)
Krout v. Goemmer, 583 F.3d 557 (8th Cir. 2009) (intervening to prevent excessive force; failure-to-protect analysis)
Hickey v. Reeder, 12 F.3d 754 (8th Cir. 1993) (unjustified use of force violates Eighth Amendment; relevant for pretrial detainees)
United States v. Miller, 477 F.3d 644 (8th Cir. 2007) (cruel and unusual punishment standard for force)
Thompson v. Zimmerman, 350 F.3d 734 (8th Cir. 2003) (summary-judgment qualified-immunity reversal where excessive force occurred by guard)
Owens v. Scott Cnty. Jail, 328 F.3d 1026 (8th Cir. 2003) (due-process protection parallels with Eighth Amendment for detainees)