Seventh Circuit Appellate Court Grants Qualified Immunity to Jail Superintendent for his Decision to Place Inmate in Restraint Chair

June 27, 2018

Earlier this month, the Seventh Circuit considered an appeal in Broadfield v. McGrath pressed by officials of Livingston County that they were entitled to summary judgment in a case filed by a mentally ill inmate who claimed that he was not properly cared for when he had a mental breakdown in the Livingston County Jail. In that case, the inmate (Brian Broadfield) become unhinged when jail officials tried to move him to a different wing of the jail after he got into an altercation with another inmate over the television programming in his wing. Broadfield refused the transfer, stated that he was going to go on a hunger strike, and then started to punch himself in the face after he was moved to a special cell in the booking wing of the jail. Broadfield was placed in a suicide-proof cell but continued to hurt himself and ultimately kicked and broke the glass window of the door in the cell. During this time Broadfield was insisting that he be placed in a restraint chair and his request was granted by the jail’s superintendent, with the inmate remaining in a restraint chair for over six hours before ultimately being taken out of the chair at the end of the day.

In his lawsuit, Broadfield claimed that he should have been placed in a restraint chair sooner and also that correctional officers used excessive force at the end of the day when they took him out of the restraint chair (during which time correctional officers used tight wrist locks and a hog-tie to move Broadfield from one cell in booking to another). The district court had refused to grant summary judgment in the case, but the Seventh Circuit reversed in part, holding that the jail’s superintendent was entitled to qualified immunity for his decisions to place Broadfield in a restraint chair and to remove him from the chair at the end of the day. The Seventh Circuit explained that the question was not whether an official had chosen “the best possible course of action” but whether the official’s conduct suggested “something approaching total unconcern for the prisoner’s welfare in the face of serious risks.” Noting that the superintendent’s conduct did not suggest a lack of concern for Broadfield’s safety, the Court also held that the law does not require that an official immediately contact a mental health provider when faced with a seemingly mentally ill inmate who is acting out. However, the court refused to grant summary judgment on Broadfield’s excessive force claim, noting that Broadfield was denying that he was still actively resisting officers at the end of the day and that it was unclear from the record whether the correctional officers had needed to use wrist locks and a hog-tie during Broadfield’s cell transfer at the end of the day. Mike Bersani and Jason Rose represented the defendants in the case.

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