Segrain v. Duffy, 118 F.4th 45

Joseph Segrain, an inmate at Rhode Island’s maximum-security prison, alleged excessive force under the Eighth Amendment and state law after an incident where correctional officers performed a leg-sweep, used pepper spray on him, and delayed his decontamination.
Incident took place on June 28, 2018: after a dispute over the duration of out-of-cell time, officers handcuffed Segrain while he still held prison-issued shower supplies, including a razor.
While handcuffed and escorted, an officer performed a leg-sweep, taking Segrain to the ground; immediately after, Officer Duffy sprayed him twice in the face with pepper spray.
Segrain was left handcuffed and in pain in a holding cell for approximately 13 minutes without immediate decontamination; a further delay occurred before he received a decontamination shower.
The district court granted summary judgment for the officers on all federal and state claims; Segrain appealed, mainly asserting the leg sweep, pepper-spray use, and decontamination delay were Eighth Amendment violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Leg Sweep Excessive Force	Leg sweep was excessive and not clearly necessary; Segrain had insufficient time to comply.	Glendinning used appropriate force given perceived threat from razor.	Qualified immunity for officer; no clearly established law that such force was unconstitutional.
Duffy’s Use of Pepper Spray	Use of pepper spray was excessive, unnecessary as Segrain was subdued and not resisting.	Necessary to maintain order due to threat posed by retained razor.	Sufficient evidence for a constitutional violation; not entitled to qualified immunity—remanded for trial.
Delay in Decontamination	Prolonged pain and lack of rapid decontamination was cruel and unusual punishment.	Any delay was justified by operational concerns (flooding, staffing); no malice.	Qualified immunity applies—no robust consensus that delay constituted a constitutional violation.
State Law Claims and State Constitutional Claim	State claims mirror federal claims; excessive force applies to state constitution, too.	State law standards differ; immunity analogues to federal.	State constitutional claim remanded for legal question; other tort claims waived for lack of argumentation.

Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment excessive force standard does not require significant injury)
Wilkins v. Gaddy, 559 U.S. 34 (Excessive force focus is on force used, not injury)
Whitley v. Albers, 475 U.S. 312 (Subjective prong: force applied in good faith vs. maliciously)
Hafer v. Melo, 502 U.S. 21 (Section 1983 action for damages against state actors)
Hope v. Pelzer, 536 U.S. 730 (Prison regulations relevant for qualified immunity/clearly established law)
United States v. Lanier, 520 U.S. 259 (General statements of law can give clear warning to officers)