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$99,000 to Settle Claim Over Use of Four-Point Restraints

by Christopher Zoukis

The federal Bureau of Prisons settled a claim that alleged abusive use of "four-point" restraints in United States Penitentiary Atlanta, Georgia in the late 1990s.

Three prisoners held at USP Atlanta who were subjected to immobilization in four-point restraints filed suit over the practice in federal district court in April 1998. According to complainants Jeff Dorsey, Anthony Miller, and Lealon Muldrow, "The limbs of a person in a four-point restraint are chained to the four corners of a bed frame, leaving him fixed in a spread-eagled position and completely unable to move or tend to normal bodily needs and functions."

The three prisoners alleged that prison guards at USP Atlanta routinely placed unresisting prisoners in four-point restraints for days or even weeks at a time. They alleged that this practice violated the Eighth Amendment prohibition on cruel and unusual punishment, the Fifth Amendment prohibition of unreasonable physical restraint, and the Fifth Amendment guarantee of due process.

The prisoners sued Thomas Keohane III, captain/acting assistant warden of USP Atlanta; lieutenants Dony Cartrette, Roy Ward, and M. Battley of USP Atlanta; Willie Scott, warden of USP Atlanta; and Robert T, Matthews, southeast regional director of the Bureau of Prisons.

The allegations made by the prisoners indicate that the use of torture was a regular practice at USP Atlanta in the late 1990s.

Lealon Muldrow alleged that Lieutenant Cartrette and others beat him to the ground while he was handcuffed, and then jumped on his back. He suffered multiple bruises on his body, head and face, as well as a cut on his forehead that required stitches, as a result of the beating.

He also ended up in four-point restraints.

Muldrow alleged that he was kept chained to a bunk on his back and spread eagle, for five full days. For the first three days, he was not allowed out of the restraints for any reason, and thus was forced to defecate and urinate on himself.

Anthony Miller alleged that he ended up in four-point restraints after defending himself from an attack by USP Atlanta prison guard Russell Jones. He was kept in the restraints for six days, and not allowed out of them at all for two days. He was forced to urinate on himself, and staff refused to change his bed sheets.

Jeff Dorsey alleged that he was placed in four-point restraints after he refused to submit to handcuffs for fear of being assaulted by the USP Atlanta prison guards wanting to handcuff him. A special operations response team ultimately entered Dorsey's cell, beat him to the ground, and placed him in four-point restraints, where he remained for three and a half days, covered by a blood-soaked sheet.

While it is not clear what happened to the constitutional claims of torture made by prisoners Dorsey and Miller, Lealon Muldrow settled his own claim on March 9, 2001. He released all of his claims against the individuals, as well as the United States, in exchange for a cash payment of $99,000.

As is typical of such a settlement, neither the defendant prison guards nor the Bureau of Prisons admitted any liability.

Plaintiffs were represented by attorneys Marion Chartoff, Tamara H. Serwer, Katharine A. Huffman, Robert E. Toone and Stephen B. Bright of the Atlanta, Georgia-based Southern Center for Human Rights, and Courtland L. Reichman of the firm King & Spaulding.

The documents from this case were obtained by Prison Legal News after prevailing in a 12-year court battle with the Bureau of Prisons over a Freedom of Information Act records request.

See: Muldrow v. Keohane, et al., United States District Court for the Northern District of Georgia, Civil Case No. 1:98-CV-0919-BBM.

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Muldrow v. Keohane


 

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