Story v. Stansifer
4:20-cv-00944
E.D. Ark.Dec 14, 2021Background
- Plaintiff Kendrick Story, an ADC inmate, alleges that on Feb. 11, 2019 he was found unresponsive or having a panic attack in his barracks and was cuffed, shackled, and chained by officers to a red trash cart for transport to the infirmary.
- Defendants (Stansifer, Baker, Turner, Green, Evans) responded to a Code 4; they transported Story on the cart to the infirmary believing he had overdosed on synthetic drugs (later negative drug tests).
- Plaintiff claims Eighth Amendment violations: deliberate indifference to medical needs, excessive force, and humiliation (transport on a trash cart); he seeks compensatory and punitive damages.
- Medical records and video show Plaintiff was brought to the infirmary on the cart, observed, had vitals recorded, and exited the infirmary on the cart; no medical staff removed him from the cart.
- Court found no evidence any defendant knowingly disregarded a serious medical need or acted maliciously/sadistically; Plaintiff also failed to show defendants knew of his panic disorder/degenerative back condition.
- Procedurally, defendants moved for summary judgment (granted); Plaintiff’s cross-motion denied; official-capacity claims dismissed on Eleventh Amendment grounds; unserved Defendant Jones dismissed without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Official-capacity damages | Story seeks damages from officers in official capacity | Official-capacity claims are state actions barred by Eleventh Amendment | Dismissed: Eleventh Amendment bars §1983 damages against State actors in official capacity |
| Deliberate indifference to medical needs | Officers violated AD-833 and should have summoned infirmary staff; transporting/shackling an unresponsive inmate delayed/denied care | Officers reasonably believed overdose; immediately transported Story to infirmary for treatment | Denied: no factual showing defendants knew of and deliberately disregarded a serious medical need; taken to infirmary promptly |
| Excessive force | Shackling Story with hands over head and leg irons and chaining to cart was malicious and caused injury | Restraints were security measures reasonably used to transport a possibly overdosing, unresponsive inmate | Denied: force used to secure/transport, not shown malicious/sadistic; qualified immunity would apply |
| Human dignity / transport on trash cart | Transporting on a trash cart was degrading and violated dignity (Eighth Amendment) | Cart had no visible trash, was the available fast means to reach infirmary; no unsanitary or unsafe conditions shown | Denied: conditions did not rise to level of Nelson/Zefferi-type dignity violation; alternative means not shown; qualified immunity applies |
Key Cases Cited
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (1998) (official-capacity damages claims are claims against the state and barred by the Eleventh Amendment)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference standard for prisoners' medical care)
- Wilkins v. Gaddy, 559 U.S. 34 (2010) (excessive-force inquiry focuses on whether force was applied maliciously and sadistically)
- Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for use-of-force claims)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified-immunity two-step analysis and flexibility in order of inquiry)
- Saucier v. Katz, 533 U.S. 194 (2001) (qualified-immunity framework)
- Roper v. Simmons, 543 U.S. 551 (2005) (Eighth Amendment and human dignity principles)
- Brown v. Plata, 563 U.S. 493 (2011) (Eighth Amendment respect for human dignity in correctional context)
- Morris v. Zefferi, 601 F.3d 805 (2010) (transport in unsanitary small cage raised serious dignity/Eighth Amendment concerns)
- Nelson v. Correctional Medical Services, 583 F.3d 522 (2009) (restraints on a woman in labor implicated dignity and Eighth Amendment)
- Casey v. Lewis, 834 F. Supp. 1477 (D. Ariz. 1993) (security staff interference with medical care can constitute deliberate indifference)
- Dulany v. Carnahan, 132 F.3d 1234 (1998) (deliberate indifference may be shown by denial/delay of access to care)
- Schaub v. VonWald, 638 F.3d 905 (2011) (definition of a serious medical need)
- Jackson v. Gutzmer, 866 F.3d 969 (2017) (Eighth Amendment excessive force analysis)