Ealom v. Ohio Dept. of Rehab. & Corr.

Citations

• 2025 Ohio 3141

Syllabus

Negligence; Excessive Force; Ohio Administrative Code. Plaintiff, an inmate, alleged that Ohio Department of Rehabilitation and Correction (\ODRC\) correctional officers used excessive force by deploying Oleoresin Capsicum spray during a fight and then failed to properly decontaminate him. The negligence claim proceeded to trial, where the magistrate found that Defendant did not breach its duty of care. Because Plaintiff ignored oral commands, remained unrestrained, and posed a continued threat, the use of force was deemed reasonable under Ohio Adm.Code 5120-9-01. The magistrate also determined that Defendant provided prompt and adequate decontamination and medical care, including immediate removal to fresh air, nursing evaluations, and ongoing treatment for eye irritation. Accordingly, the magistrate recommended judgment in favor of Defendant.