Thomas Alexander v. Sergeant Connor
105 F.4th 174
4th Cir.2024Background
- Plaintiff Thomas Alexander, an incarcerated individual at Eastern Correctional Institution (NC), alleged two correctional officers used excessive force during a search for a contraband cellphone.
- Officers claimed the phone was found in Alexander’s pocket; Alexander alleged it was forcibly extracted from his rectum after he was pepper-sprayed and restrained in a shower room.
- Alexander brought suit under 42 U.S.C. § 1983, claiming violations of the Fourth and Eighth Amendments.
- The district court granted summary judgment to the officers, relying largely on a partially obstructed security video and finding Alexander’s account incredible.
- The Fourth Circuit reviewed the grant of summary judgment de novo and considered whether factual disputes precluded summary judgment for the defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment was proper | Material factual disputes require jury resolution | Video and record broadly discredit plaintiff's account | Summary judgment improper; factual disputes remain |
| Fourth Amendment violation (search) | Search was an invasive, unreasonable cavity search | Search was limited, justified given contraband concerns | Jury could find search unreasonable under Fourth |
| Eighth Amendment violation (force) | Force was excessive, unnecessary, and punitive | Only necessary force to control plaintiff’s resistance | Jury could find excessive force in violation |
| Weight of video evidence at summary | Video does not directly contradict plaintiff’s story | Video supports officers, makes plaintiff’s claim untenable | Video does not blatantly contradict plaintiff |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (2007) (video evidence can override a plaintiff’s version only if it incontrovertibly contradicts that account)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard requires all evidence viewed in non-movant’s favor)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (burden shifting on summary judgment)
- Bell v. Wolfish, 441 U.S. 520 (1979) (scope of permissible searches in prison)
- Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment applies in prison environment)
- Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment standard for excessive force in prisons)
- King v. Rubenstein, 825 F.3d 206 (4th Cir. 2016) (prisoners retain some Fourth Amendment privacy in their person)
- Whitley v. Albers, 475 U.S. 312 (1986) (subjective standard for Eighth Amendment excessive force)