Claim Denied; No Proof New York Prison Guards Acted Within Scope of Their Employment
On June 13, 2018, the New York Court of Claims in Saratoga Springs found in favor of prison guards accused of assaulting a prisoner without provocation. Although it was undisputed that the prisoner had been beaten, he failed to prove the guards were responsible and, even if they were, “did not demonstrate that [they] were acting within the scope of their employment.”
The incident took place at the Greene Correctional Facility on September 8, 2015. Prisoner Chanlie Valentin was smoking a cigarette with four other prisoners when guard Jerome Gales approached them. The four other prisoners left before they could be confronted, leaving Valentin alone with the guard. Valentin claimed that Gales told him to go back to his cubicle, cursed at him and repeatedly struck him; when he protested, Gales told him to report to the sergeant’s office.
Inside the office, Valentin was made to sit in a chair with his hands under his legs. He alleged he was then assaulted by multiple guards while being questioned by Sgt. Bruce Chamberlain until he falsely confessed that he had been attacked by three other prisoners. Valentin sustained a broken nose, broken eye socket and other injuries. The guards named in his suit, however, contended they were not responsible for his injuries and that Valentin had in fact been assaulted by fellow prisoners.
“Two drastically different and irreconcilable versions of the events of September 8, 2015 were presented at trial, leaving the Court to credit one and reject the other, or reject them both,” the Court of Claims wrote. “Claimant’s case presented an unprovoked assault and battery by CO Gales, Sgt. Chamberlain and others, while defendant presented proof that claimant had been assaulted not by staff, but allegedly by three inmates.
“If the Court were to credit defendant’s version of the events, the claim of assault by defendant’s employees would be dismissed for failure to establish a prima facie case. On the other hand, if the Court were to fully credit claimant’s version and find that he had been assaulted by defendant’s employees as he testified, defendant would not be found liable to claimant for the acts of its employees because the preponderance of the credible evidence fails to demonstrate that the correction officers were acting within the scope of their employment when they viciously assaulted him without provocation.”
The court concluded that Valentin had “failed to prove by a preponderance of the credible evidence that he was subjected to an assault and battery by defendant’s agents while acting within the scope of their employment or that defendant was aware of the propensity of its agents to perpetrate such an assault.” As such, the state could not be held liable. See: Valentin v. State of New York, New York State Court of Claims, Claim No. 127111.
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Related legal case
Valentin v. State of New York
|Cite||New York State Court of Claims, Claim No. 127111|
|Level||Court of Claims|