Force That Resulted In Injury To Arrestee Was Reasonable When It Would Not Have Led To Injury In Typical Arrestee And Officers Were Unaware Of His Sensitivity
STAINBACK v. DIXON (June 30, 2009)
Several police officers, after a report of his involvement in a minor disturbance, arrested Charles Stainback. They asked Stainback to put his hands behind his back. Instead of doing so, he asked that he not be handcuffed. All he said was that he thought it would hurt. The officers handcuffed him anyway. Stainback was handcuffed in a police vehicle for approximately 20 minutes. During that time, he complained that the handcuffs were hurting him and asked for them to be removed. Stainback alleges that he required medical treatment as a result of the episode. He sued the officers, alleging the use of excessive force. The lower court concluded that the officers were entitled to qualified immunity because the amount of force was reasonable under the circumstances. The court granted summary judgment to the police officers. Stainback appeals.
In their opinion, Judges Flaum, Ripple and Sykes affirmed. The Court stated that whether force is reasonable depends on the circumstances surrounding the arrest. The circumstances must be viewed as they would have been by a reasonable officer on the scene. Here, the officers used an amount of force that would not have harmed a typical arrestee. Given that the officers were not aware that Stainback suffered from any particular condition or injury, the Court concluded that their actions were reasonable.
