Easley v. Dept. of Rehab. & Corr.
2017 Ohio 2700
| Ohio Ct. Cl. | 2017Background
- Plaintiff Dave Easley, an inmate, alleged that on July 1, 2016 corrections officers searching his cell retaliatorily assaulted and sexually abused him (inserting a finger into his rectum), slammed his head into a wall, and beat him out of camera view; he also alleged denial of a PREA investigation.
- Defendant (Ohio Department of Rehabilitation & Correction) moved for summary judgment; Easley did not file a response.
- Defendant submitted sworn affidavits from COs Dotson, Dofflemyer, Captain Clark, and Lt. Smith denying any sexual contact, assault, threats, or excessive force and describing inmate noncompliance and discovery of pills in the mattress.
- Officers describe using control techniques after Easley disobeyed direct orders (refused drug testing and resisted escort), placed him in handcuffs, and moved him to security control.
- The court applied Civ.R. 56 standards and Civ.R. 56(E) (adverse party must respond with specific facts) and concluded no genuine issue of material fact existed to contradict defendants’ affidavits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Assault / Battery / Excessive force | Easley alleges sexual assault (digital anal penetration), head slammed to wall, and beatings | Officers deny any inappropriate touching, slamming, punching, or threats; state force used only to control noncompliant inmate | Summary judgment for defendant: no genuine disputed fact; force was limited to control and not excessive |
| Negligence (failure to protect / use of force) | Officers breached duty of care by assaulting and abusing Easley | Officers acted within authority and used reasonable force under circumstances (inmate noncompliance, contraband discovery) | Summary judgment for defendant: no evidence of breach or proximate injury beyond lawful control measures |
| Failure to initiate PREA investigation | Easley alleged PREA complaint was not investigated | Defendants show Captain Clark contacted PREA support/coordinator; denies retaliatory motive | Court found no admissible evidence from Easley to create fact issue; summary judgment for defendant |
| Procedural adequacy of summary judgment | Easley contends allegations entitle him to trial | Defendant argues its affidavits meet summary-judgment burden and Easley’s failure to respond is fatal under Civ.R. 56(E) | Court held summary judgment appropriate; adverse party’s lack of response required specific facts to oppose and none were provided |
Key Cases Cited
- Gilbert v. Summit Cty., 104 Ohio St.3d 660 (2004) (summary judgment standard and construction of evidence against nonmoving party)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (1977) (summary judgment principles and burdens)