Glenn Howell v. Victor HIll
23-14218
| 11th Cir. | Mar 4, 2025Background
- Glenn Howell was a pretrial detainee at Clayton County Jail in 2020.
- Howell alleges then-Sheriff Victor Hill left him, while compliant and nonresistant, handcuffed in a restraint chair for over four hours as punishment.
- Howell filed a § 1983 claim against Hill in his individual capacity for excessive force in violation of the Fourteenth Amendment.
- Hill sought summary judgment based on qualified immunity, which the district court denied.
- While this appeal was pending, the Eleventh Circuit affirmed Hill’s criminal conviction based on the same conduct, holding it constitutionally excessive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified immunity for alleged excessive force | Howell’s rights were clearly established and violated by Hill’s conduct | Hill is entitled to qualified immunity as conduct did not violate clearly established law | Qualified immunity denied; law was clearly established |
Key Cases Cited
- United States v. Hill, 99 F.4th 1289 (11th Cir. 2024) (affirming criminal conviction for unconstitutional use of restraint chair on compliant detainees)
- Nelson v. Tompkins, 89 F.4th 1289 (11th Cir. 2024) (qualified immunity analysis standard)
- Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1289 (11th Cir. 2005) (binding effect of prior panel precedent)
- Hope v. Pelzer, 536 U.S. 730 (2002) (standard for determining clearly established constitutional rights)