Edgerton v. Hillard
2:23-cv-00693
| D. Nev. | Jun 30, 2025Background
- Plaintiff Edward Edgerton, Jr., a Black inmate at Southern Desert Correctional Center, sued Correctional Officer Alexander Hillard for excessive force and racial discrimination during a 2021 incident.
- Edgerton contends that when seeking to download music from a kiosk, Hillard threatened him with pepper spray, used profane language, and forced him into a painful search position, allegedly kicking his feet and ankles.
- Edgerton claims he complied with Hillard’s orders before the use of force, and suffered a lingering foot injury as a result.
- Hillard asserts Edgerton disobeyed commands to leave the gym, acted aggressively, force used was minimal and only to complete a necessary search, and denies any racial motivation or use of excessive force.
- Both parties dispute whether Edgerton’s injuries were related to the incident, as the medical records primarily reflect treatment for other ailments.
- Hillard sought summary judgment on the grounds of de minimis force, qualified immunity, lack of discriminatory motive, and absence of a basis for punitive damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment Excessive Force | Force more than de minimis; he complied | Force was minimal and justified by noncompliance | Denied summary judgment; jury could find excessive force |
| Qualified Immunity | Not directly addressed, but cites clear law | No clearly established law prohibiting his conduct | Denied; law clearly prohibits malicious force on compliant inmate |
| Fourteenth Amendment Equal Protection | Treated worse than similarly situated inmate due to race | Differential treatment based on conduct, not race | Denied; jury could find discriminatory intent |
| Punitive Damages | Suffered pain from malicious conduct | No serious injury; no malicious intent | Denied; sufficient evidence of malice for punitive damages |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard—material fact/genuine dispute)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting framework)
- Whitley v. Albers, 475 U.S. 312 (Eighth Amendment: excessive force requires wanton infliction of pain)
- Hudson v. McMillian, 503 U.S. 1 (unnecessary and wanton infliction of pain violates Eighth Amendment, regardless of significant injury)
- Wilkins v. Gaddy, 559 U.S. 34 (core inquiry is nature of force, not extent of injury)
- Wolff v. McDonnell, 418 U.S. 539 (prisoners protected from discrimination based on race)
- Barren v. Harrington, 152 F.3d 1193 (equal protection claim requires intent or purpose to discriminate)
- Martinez v. Stanford, 323 F.3d 1178 (factors for excessive force analysis under Eighth Amendment)