Mike Newcastle v. L. Adams, 690 F. App'x 542

Plaintiff Mike Newcastle, a prison inmate, sued under 42 U.S.C. § 1983 claiming Eighth Amendment excessive force and related deprivations by officers Renee Baker and James Bruffy.
District court granted summary judgment for both defendants; Newcastle appealed.
Newcastle failed to exhaust administrative remedies as to claims against Baker (humiliation, property/clothing deprivation, sleep loss); district court therefore granted judgment for Baker.
Newcastle relied on criminal trial transcripts and eyewitness testimony to oppose summary judgment; the district court excluded the transcripts as hearsay sua sponte.
For Bruffy, the district court found Newcastle’s excessive-force claim implausible and uncorroborated, relying partly on video evidence; the Ninth Circuit found that court failed to view evidence in Newcastle’s favor.
The Ninth Circuit reversed as to Bruffy (genuine dispute of material fact) and affirmed as to Baker (failure to exhaust); it also held the district court abused discretion by excluding trial transcripts without objection and prejudicing Newcastle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion re: Baker	Newcastle argued his grievance encompassed Baker’s conduct	Baker argued grievance did not raise humiliation/property/sleep claims	Held for Baker: grievance did not exhaust those claims; summary judgment affirmed for Baker
Admissibility of criminal trial transcripts	Transcripts corroborate Newcastle’s version and should be admitted	Defendants did not object; district court excluded as hearsay	Held for Newcastle: exclusion sua sponte was an abuse of discretion and prejudicial
Sufficiency of evidence re: Bruffy excessive force	Newcastle presented video gaps, medical records, and witness corroboration creating triable issue	Bruffy relied on video and argued Newcastle’s account was implausible and uncorroborated	Held for Newcastle: genuine dispute of material fact exists; summary judgment for Bruffy reversed
Standard for resolving conflicts with video evidence	Newcastle argued video did not blatantly contradict his testimony for critical minutes	Defendants argued video undermined Newcastle’s account	Held for Newcastle: video did not blatantly contradict testimony; evidence must be viewed in plaintiff’s favor

Albino v. Baca, 747 F.3d 1162 (9th Cir. 2014) (standard of review for exhaustion rulings)
Blankenhorn v. City of Orange, 485 F.3d 463 (9th Cir. 2007) (standard of review for summary judgment)
McKenzie v. Lamb, 738 F.2d 1005 (9th Cir. 1984) (summary judgment requires no genuine dispute of material fact)
Orr v. Bank of Am., NT & SA, 285 F.3d 764 (9th Cir. 2002) (review of evidentiary exclusions for abuse of discretion)
Griffin v. Arpaio, 557 F.3d 1117 (9th Cir. 2009) (scope of grievances for exhaustion)
Ivey v. Bd. of Regents of Univ. of Alaska, 673 F.2d 266 (9th Cir. 1982) (limits of liberal construction of civil rights complaints)
Fonseca v. Sysco Food Servs. of Arizona, Inc., 374 F.3d 840 (9th Cir. 2004) (impropriety of sua sponte evidentiary rulings without opportunity to respond)
Scott v. Harris, 550 U.S. 372 (2007) (when video blatantly contradicts testimony such that testimony can be disregarded)
Young v. County of Los Angeles, 655 F.3d 1156 (9th Cir. 2011) (application of Scott to video evidence)