Story v. Norwood, 659 F.3d 680

On May 22, 2007, Story, an Arkansas inmate, was in B-Pod when inmates caused a riot-like disturbance including flooding and lights being broken.
Norwood, a jail administrator, ordered inmates to get on the wall; Story refused to comply, and Norwood twice pushed Story toward the wall while holding a flashlight and threatened a taser to maintain control.
Story contends Norwood struck him with the flashlight; three inmates and Gill testified to different versions, some alleging multiple hits, Story denying such blows.
Medical evaluation soon after found only a left elbow contusion; x-rays showed no fracture, and later doctors diagnosed chronic conditions (degenerative disc disease) not clearly linked to the incident.
The magistrate judge found Norwood’s force to be minimal and reasonable given emergent circumstances, and the district court adopted those findings.
Story's § 1983 claim proceeded against Norwood but was dismissed with prejudice after the district court held Norwood’s force was necessary and reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Norwood used excessive force.	Story contends Norwood struck him, making force excessive.	Norwood argues force was minimal, necessary to restore order under emergent conditions.	No excessive force; force was reasonable and minimal.
Whether the district court’s credibility determinations were clearly erroneous.	Story asserts the district court erred in crediting Norwood and Gill over Story’s version.	Defendant maintains credibility determinations are for the district court and supported by evidence.	Credibility findings not clearly erroneous; supported by substantial evidence.
Whether emergent circumstances justified use of force.	Story asserts there was no ongoing threat justifying force.	District court found riot-like conditions and flooding requiring control.	Emergent circumstances justified some force to regain control.
Whether the district court incorrectly required a threshold injury to prove excessive force.	Story argues injury need not be significant to show excess force.	Court weighed credibility and medical evidence rather than mandating injury level.	Legal standard correctly applied; no threshold injury requirement enforced.

Graham v. Connor, 490 U.S. 386 (1989) (establishes reasonableness standard for force in context)
Hudson v. McMillian, 503 U.S. 1 (1992) (de minimis injuries may still violate if force is malicious or sadistic)
Walker v. Bowersox, 526 F.3d 1186 (8th Cir. 2008) (factors for evaluating reasonableness of force)
Hartsfield v. Colburn, 491 F.3d 394 (8th Cir. 2007) (review of district court’s factual findings under clear error standard)
Anderson v. City of Bessemer City, 470 U.S. 564 (1985) (credibility determinations given high deference)
U.S. Gypsum Co. v. United States, 333 U.S. 364 (1948) (standard for reviewing factual conclusions)