In re Guardianship & Conservatorship of Alice H.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that “de minimis or trivial force is not enough” under the subjective prong
• holding that a correctional officer was not entitled to qualified immunity where the officer had his knee on the inmate’s chest and directly blasted pepper spray into the face of the completely restrained and non- resisting inmate who was on the ground with his hands cuffed behind him
• laying our four non-exhaustive factors to determine whether an officer’s conduct met the subjective prong by establishing wantonness
• asking “whether force was applied in a good faith effort to maintain or restore discipline or maliciously and sadistically for the very purpose of causing harm” (emphasis added) (citation omitted)
• pepper-spraying a fully restrained, face-down inmate who headbutted officer raised inference of malice
• finding question whether officer’s use of pepper spray was clearly necessary was a sharply contested question of fact; viewing the contested facts in the light most favorably to the inmate, a reasonable jury could find he was pepper-sprayed only after any threat to safety had passed

Source: CourtListener parenthetical corpus (CC0).