McClendon v. Department of Juvenile Justice
701 F. App'x 771
| 11th Cir. | 2017Background
- McClendon, a juvenile detainee at Metro Regional Youth Detention Center, had a blanket covering the window of his solid-steel cell door to block light.
- During routine rounds, guard Christopher Williams ordered McClendon to remove the blanket; McClendon began to comply while holding the blanket in the door seam.
- Video evidence shows McClendon pushed the door open quickly and held it open as Williams attempted to close it; Williams ultimately shut the door, crushing three of McClendon’s fingers and causing partial amputation of a middle finger.
- McClendon sued under 42 U.S.C. § 1983, alleging Eighth Amendment excessive force; the district court dismissed other claims and granted Williams summary judgment on the Eighth Amendment claim.
- On appeal, the Eleventh Circuit reviewed the video and concluded it conflicted with McClendon’s description of events; the court held no reasonable jury could find Williams acted maliciously and sadistically.
- McClendon attempted to raise a deliberate-indifference-to-medical-needs argument on appeal, but the court declined to consider it because it was not pleaded in the operative complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams used excessive force in violation of the Eighth Amendment | Williams slammed the door on McClendon’s hand while McClendon was complying, causing severe injury; this was malicious and sadistic force | Video shows McClendon pushed and held the door open, appearing to try to escape; Williams’ closing the door was a security response, not malicious force | No excessive force; summary judgment for Williams affirmed |
| Whether video evidence controls over plaintiff’s testimony at summary judgment | Plaintiff urged that his deposition testimony created a genuine dispute | Defendant relied on surveillance video that contradicts plaintiff’s version | Video depiction accepted; facts viewed in light depicted by videotape |
| Whether negligence or delayed medical attention supports Eighth Amendment claim | Plaintiff argued Williams’ failure to treat injuries showed deliberate indifference | Defendant noted no deliberate-indifference claim in operative complaint and contested constitutional violation | Court refused to consider deliberate-indifference argument raised first on appeal; not considered |
| Whether summary judgment was appropriate given record viewed in light most favorable to nonmoving party | Plaintiff asserted genuine issues of material fact existed warranting trial | Defendant contended no reasonable jury could find malicious intent given video and circumstances | Summary judgment appropriate because no genuine issue of material fact about malicious/sadistic intent |
Key Cases Cited
- Hamilton v. Southland Christian Sch., Inc., 680 F.3d 1316 (11th Cir. 2012) (summary judgment standard and view of evidence favorable to nonmoving party)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Sup. Ct.) (standard for genuine dispute of material fact)
- Pourmoghani-Esfahani v. Gee, 625 F.3d 1313 (11th Cir. 2010) (video evidence that contradicts plaintiff controls over plaintiff’s testimony)
- Scott v. Harris, 550 U.S. 372 (Sup. Ct.) (courts may view facts in the light depicted by videotape when tape contradicts plaintiff)
- Campbell v. Sikes, 169 F.3d 1353 (11th Cir. 1999) (excessive-force standard: malicious and sadistic intent required)
- Whitley v. Albers, 475 U.S. 312 (Sup. Ct.) (use of force in prison security measures not an Eighth Amendment violation simply because it seems unreasonable in hindsight)
- Gilmour v. Gates, McDonald & Co., 382 F.3d 1312 (11th Cir. 2004) (cannot raise new claims for the first time at summary judgment or on appeal)