Gregory Robinson v. Carl Danberg
673 F. App'x 205
| 3rd Cir. | 2016Background
- Gregory Robinson, convicted in 2008, sued prison officials under the Fourteenth Amendment (pretrial incidents) and the Eighth Amendment (post-conviction incidents) for excessive force and unconstitutional conditions spanning 2008–2010 at James T. Vaughn Correctional Center.
- Pretrial excessive-force claim: Robinson alleges Officer Beckles injured his hand while removing handcuffs after returning him to a locked cell; Beckles asserts Robinson resisted and tried to yank his hand away.
- Post-conviction excessive-force claims: Robinson alleges Officer Downing struck him in the face during a cell shakedown, and Officer DeAllie sprayed mace into Robinson’s locked cell; Robinson submitted inmate declarations supporting the macing claim.
- Pretrial conditions claims: Robinson alleged prolonged exposure to toilet water, being forced to clean a blood-stained cell without protection, and urine sprayed into his cell; evidence of severity/duration was sparse.
- Post-conviction conditions claims: Robinson alleged foreign objects in food, repeated door-pounding/wake-ups causing sleep deprivation, and staff calling him a "snitch" in earshot of inmates; district court granted summary judgment on these claims.
- Procedural posture: District Court granted summary judgment for defendants on all claims; Third Circuit affirms in part, reverses/vacates in part, and remands several excessive-force claims for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pretrial excessive force (Beckles) — hand injury when uncuffing | Beckles removed cuffs while Robinson locked in cell and not resisting, causing a gash; force was punitive under Fourteenth Amendment | Beckles says Robinson ignored orders and actively resisted when being uncuffed, creating security risk | Vacated and remanded: district court erred by relying solely on minor injury; must assess all Kingsley factors and view facts in plaintiff’s favor |
| Post-conviction excessive force (Downing) — alleged punch to face | Downing struck Robinson in mouth/face during September 2009 incident, amounting to Eighth Amendment excessive force | Defendants focused on false-report theory and contested occurrence; district court analyzed due process aspects instead | Vacated and remanded: district court failed to address Robinson’s Eighth Amendment excessive-force claim on the merits |
| Post-conviction excessive force (DeAllie) — macing in locked cell | DeAllie sprayed mace into a locked cell where Robinson posed no threat; inmate declarations and investigation notes support occurrence | Defendants pointed to lack of incident report/logbook and characterized any force as de minimis | Reversed: genuine disputes of fact exist about occurrence and severity; claim survives summary judgment and is remanded for trial |
| Conditions of confinement (pre- and post-conviction claims: toilet/blood/urine, foreign objects, sleep deprivation, being called a snitch) | Conditions and intentional harassment deprived Robinson of minimal civilized necessities and created risk of harm | Defendants argue incidents were isolated, insufficiently severe, or unsupported by evidence; no deliberate indifference shown | Affirmed: evidence is too sparse or not objectively serious; summary judgment for defendants proper on these claims |
Key Cases Cited
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (pretrial detainee excessive-force standard: objective-unreasonableness and Kingsley factors)
- Bell v. Wolfish, 441 U.S. 520 (1979) (standard for punitive conditions against pretrial detainees)
- Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment excessive-force: malicious and sadistic vs. good-faith discipline)
- Whitley v. Albers, 475 U.S. 312 (1986) (factors for evaluating use of force in prison contexts)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference and duty to protect inmates)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment: genuineness of factual disputes and view of evidence)
- Brooks v. Kyler, 204 F.3d 102 (3d Cir. 2000) (no fixed minimum injury requirement for Eighth Amendment excessive-force claims)
- Giles v. Kearney, 571 F.3d 318 (3d Cir. 2009) (inmate affidavit may suffice to create factual dispute at summary judgment)