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Sixth Circuit Affirms Summary Judgment for Guard Accused of Excessive Force over Use of “Leg Sweep”

The U.S. Court of Appeals for the Sixth Circuit has affirmed a grant of summary judgment for a guard accused of excessive force against a prisoner.

Trudy Griffen became disruptive during the booking process at the Davidson County Criminal Justice Center. Darrell Hardrick, a guard at the jail, performed a “leg-sweep maneuver” on Griffen, causing Griffen to fall. Pamela Rutledge, another guard involved in the tussle, fell on one of Griffen’s legs, breaking Griffen’s tibia.

Griffen argued that Hardrick’s leg-sweep was excessive force. The Sixth Circuit disagreed. Because Griffen “had been engaged in a loud, lengthy, and animated conversation [with jail staff],” the court wrote, “Hardrick [had] a reasonable basis to believe that force would be necessary to control Griffen.”

Further, the court noted, the entire incident was captured on video. The video supported the district court’s conclusion that Hardrick “was not seeking to wantonly inflict pain” on Griffen, the court concluded. See: Griffen v. Hardrick, 604 F. 3d 949
(6th Cir. 2010)

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Related legal case

Griffen v. Hardrick