Spangler v. Butler (INMATE 1)
2:16-cv-00794
M.D. Ala.Jun 13, 2017Background:
- Plaintiff Marcus Montez Spangler, an indigent Alabama state inmate, sued under 42 U.S.C. § 1983 claiming: excessive force on April 2, 2016 by officers Salter and Dudley in the health care unit; Nurse Butler failed to intervene and refused to prepare a body chart; a disciplinary charge for fighting without a weapon was unconstitutional; and he was denied medical care in July–August 2016.
- Defendants submitted special reports with affidavits, prison disciplinary records, and medical records disputing Spangler’s allegations: Salter and Dudley deny using force; Butler states she assessed and treated Spangler and completed a body chart and nursing encounter notes.
- Medical records show Spangler has schizoaffective disorder, a history of self-harm and confabulated reports to manipulate staff, and occasional refusal of prescribed medication.
- The magistrate judge ordered Spangler to respond to the defendants’ reports and warned that failure to do so could be treated as abandonment and result in dismissal.
- Spangler failed to file the required response by the deadline; the court found the defendants’ evidentiary materials uncontroverted and concluded no constitutional violations were shown.
- Recommendation: case dismissed without prejudice for failure to prosecute and failure to comply with court order; parties given deadline to object to the recommendation.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (April 2, 2016) | Spangler: Salter and Dudley used excessive force against him in health care unit | Salter/Dudley: deny using any force; records contradict claim | Dismissed; defendants' evidence unrebutted, no constitutional violation shown |
| Failure to intervene / record (Nurse Butler) | Spangler: Butler witnessed force, failed to intervene, refused to compile body chart | Butler: assessed and treated Spangler, completed body chart and nursing encounter notes | Dismissed; Butler’s records and affidavit uncontradicted |
| Disciplinary conviction (fighting without a weapon) | Spangler: disciplinary action constitutionally defective | Defendants: disciplinary records support charge (and plaintiff did not respond) | Dismissed for failure to prosecute; no developed due-process finding on merits given procedural posture |
| Denial of medical care (July–Aug 2016) | Spangler: lacked access to medical treatment during that period | Defendants: medical records show assessment and treatment on sick calls; no denial shown | Dismissed; records unrebutted showing treatment provided |
Key Cases Cited
- Moon v. Newsome, 863 F.2d 835 (11th Cir. 1989) (dismissal for failure to obey court order not an abuse of discretion when litigant was warned)
- Resolution Trust Co. v. Hallmark Builders, Inc., 996 F.2d 1144 (11th Cir. 1993) (standards on objections to magistrate recommendations)
- Henley v. Johnson, 885 F.2d 790 (11th Cir. 1989) (procedural standards regarding magistrate judge recommendations)
- Nguyen v. United States, 556 F.3d 1244 (11th Cir. 2009) (courts may take judicial notice of their own records)