Dillon v. Alvarado, 4:17-cv-00204

Plaintiff Kyle Dillon, a TDCJ inmate, sued two officers (Lt. Jose Alvarado and Officer Kyle Prentice) and a nurse (Carolyn Rose) under 42 U.S.C. § 1983 for excessive force and denial of medical care arising from an October 31, 2016 restraint/escort incident in administrative segregation.
Prison policy required administrative-segregation inmates to be handcuffed with hands behind the back; Dillon admits he "stepped through" his cuffs to move his hands to the front.
Officers report Dillon disobeyed orders and resisted; they applied forward/downward pressure and placed him prone on the concrete; other officers were summoned.
Post-incident medical records and photographs show minor abrasions/scrapes to Dillon’s face, arm, and knees; no documented concussion at the time.
Disciplinary proceedings found Dillon guilty of creating a disturbance; an administrative review concluded the officers’ use of force complied with TDCJ policy.
Defendants moved for summary judgment asserting (1) the force was necessary and not excessive, (2) medical staff provided/ documented care showing only minor injuries, and (3) qualified immunity. The court granted summary judgment for all defendants and dismissed the case with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alvarado and Prentice used excessive force in violation of the Eighth Amendment	Dillon says officers slammed him to the concrete when he stepped through his cuffs, causing scrapes and a concussion	Officers say Dillon disobeyed orders and resisted; force used was minimal, necessary, and consistent with TDCJ Use of Force plan	Court: No constitutional violation; injuries were de minimis and evidence fails to show malicious or sadistic force — summary judgment for officers granted
Whether Nurse Rose was deliberately indifferent to a serious medical need by failing to treat or document a concussion	Dillon contends Rose failed to document or treat a concussion sustained in the incident	Rose produced medical records and photos showing only minor abrasions and no contemporaneous concussion; later complaints were limited to muscle soreness	Court: No deliberate indifference; medical records contradict concussion claim — summary judgment for Rose granted
Whether defendants are entitled to qualified immunity	Dillon argues defendants violated clearly established rights and factual disputes preclude immunity	Defendants argue (and provided evidence) their actions were lawful and objectively reasonable under existing law	Court: Qualified immunity applies — plaintiff failed to rebut with specific admissible evidence; immunity affirmed

Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard for public officials)
Ashcroft v. al-Kidd, 563 U.S. 731 (two-prong clearly established-rights/violation test for qualified immunity)
Hudson v. McMillian, 503 U.S. 1 (excessive-force analysis and Hudson factors)
Whitley v. Albers, 475 U.S. 312 (use-of-force inquiry in prison context)
Wilkins v. Gaddy, 559 U.S. 34 (serious-injury not required; absence of serious injury bears on excessiveness)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Siglar v. Hightower, 112 F.3d 191 (abrasions/bruises can be de minimis in excessive-force claims)