Hayes v. Smith & Wesson
692 F. App'x 70
2d Cir.2017Background
- Plaintiff Ronald Hayes, a pro se inmate, claimed Smith & Wesson handcuffs failed to open after being over-tightened by corrections officers, requiring bolt cutters and medical treatment.
- Hayes asserted product-liability claims (manufacturing/design/warning defects) against Smith & Wesson and excessive-force/related claims against three corrections officers who tightened/punched him.
- District court granted summary judgment to Smith & Wesson on the product-liability claims and, after trial, entered judgment for the corrections officers on excessive-force claims; Hayes appealed.
- Hayes argued for adverse-inference findings based on alleged destruction/loss of the handcuffs, repair records, and prison videotapes; he also sought to reopen discovery and to adjourn trial to obtain a medical expert.
- The Second Circuit reviewed the summary-judgment and discovery/adjournment rulings for legal error and abuse of discretion and affirmed the district court for the reasons in the magistrate judge’s report.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether adverse inference warranted against Smith & Wesson for destroyed handcuffs/records | Hayes: destruction prevented proving defect; adverse inference should apply | S&W: no control of evidence when destroyed; records/old cuffs not shown relevant to manufacturing defect | No adverse inference; Hayes failed to show control, culpable state of mind, or relevance |
| Burden to exclude other causes for the handcuffs’ failure | Hayes: circumstantial evidence suffices to show defect | S&W: plaintiff must exclude other non-manufacturer causes | Held for S&W: Hayes failed to exclude alternative causes; summary judgment proper |
| Motion to reopen discovery for repair records/other cuffs | Hayes: needed additional records and info | S&W/District: discovery period had closed; Hayes had ample time earlier | Denial affirmed—no abuse of discretion; delay/late request fatal |
| Denial of adjournment to obtain medical expert | Hayes: adjournment necessary to present injury evidence | Defense/Court: trial imminent; expert disclosure deadline passed; case long pending | Denial affirmed—no arbitrary abuse; substantial prejudice to schedule if granted |
| Adverse-inference instruction against corrections officers for destroyed evidence/videotapes | Hayes: destroyed evidence would support excessive-force claim | Officers: Hayes failed to show tapes/cuffs were preserved/destroyed culpably or that items were relevant to Eighth Amendment claim | Denial affirmed—evidence (e.g., improper cuff cutting) at best showed negligence, not Eighth Amendment violation; no showing of relevance/culpable destruction |
Key Cases Cited
- Sotomayor v. City of New York, 713 F.3d 163 (2d Cir.) (standard for de novo review of summary judgment)
- McCarthy v. Olin Corp., 119 F.3d 148 (2d Cir.) (New York product-liability theories)
- Speller ex rel. Miller v. Sears, Roebuck & Co., 100 N.Y.2d 38 (N.Y.) (circumstantial proof and excluding other causes in products cases)
- Chin v. Port Auth. of N.Y. & N.J., 685 F.3d 135 (2d Cir.) (requirements for adverse-inference instruction for destroyed evidence)
- Kronisch v. United States, 150 F.3d 112 (2d Cir.) (destruction of evidence insufficient alone to defeat summary judgment)
- Ramos v. Howard Indus., Inc., 10 N.Y.3d 218 (N.Y.) (plaintiff’s burden to exclude other causes on summary judgment)
- In re Agent Orange Prod. Liab. Litig., 517 F.3d 76 (2d Cir.) (abuse-of-discretion standard for discovery rulings)
- Sequa Corp. v. GBJ Corp., 156 F.3d 136 (2d Cir.) (standards for showing denial of adjournment was arbitrary and prejudicial)
- Farid v. Ellen, 593 F.3d 233 (2d Cir.) (negligence insufficient for Eighth Amendment claim)