The complaint, which was filed on December 1, 2020, alleged claims on behalf of April Walker, LaVonna Dorsey, and Alexis Riggs. They are represented by the Abolitionist Law Center, Pennsylvania Law Project, and K&L Gates. Incident reports and use of force reports described Raible’s conduct and reflected “he repeatedly used unnecessary and unreasonable force on people with psychiatric disabilities at ACJ.” Seven specific incidents were briefly cited to support that allegation.
Walker’s ACJ medical record reflects she is asthmatic and was diagnosed with bipolar disorder, anxiety, and depression. She was two months pregnant in December 2018 when she was a detainee at ACJ. She was moved on December 12, 2018, to a filthy cell that lacked a mattress.
As she stood outside the cell in handcuffs, Walker peered into the cell and “saw a garbage bag filled with trash and stale food, milk cartons, and other detritus covered the floor.” Walker told the guard she was reluctant to move into the unsanitary cell because she feared the unsanitary conditions could endanger the health of herself and her baby. The guard responded, “Fuck this shit. I’m done dealing with this shit. I’m calling Raible.”
About a minute later, Raible arrived and without warning he pepper sprayed Walker in the face. This aggravated her asthma and caused her to cough profusely. While she was coughing, Raible slammed Walker’s face into the ground. He again pepper sprayed her. Other guards yelled at Raible that Walker was pregnant and to quit hurting her. Raible threw Walker into a shower and turned on the water. She was not allowed to dry off or change clothes before Raible took her back to the acute metal housing unit.
Raible again assaulted Walker on December 1, 2019. At that time, Walker was suffering postpartum depression following the July 4th birth of her daughter. After Raible prematurely terminated a visit with her daughter’s father, Raible slammed Walker into a wall and pinned her there while guard Jamie Merlino tased her. Walker was then placed in a restraint chair for about six hours by Raible and Merlino.
Dorsey was put in solitary confinement at ACJ on August 17, 2019, for an incident when another prisoner taunted her for several minutes by refusing to give her a food tray. Dorsey, who suffers from asthma, depression, PTSD, schizoaffective disorder and manic-depressive disorder, threatened to split on the other detainee. A misconduct ticket was issued, and the next day Raible was called to escort Dorsey to a punishment cell.
While placing handcuffs on Dorsey, Raible put his knee into her back. He then caused her extreme pain by lifting her by the cuffs. Dorsey was placed in a shower and ordered to strip. When she followed an order to throw her cloths out, her bra landed on a guard’s boot. “Assault on an officer!” a guard yelled. Raible then hit Dorsey three times with pepper spray. He aggravated the burning by turning on the hot water in the shower. Afterwards, Dorsey was placed in a restraint chair while naked. The chair was then wheeled to an intake area cell where staff and other detainees could view her. She remained in that state for about seven hours.
Diggs, who suffers from bipolar disorder, depression, anxiety, and complex PTSD, was ordered in December 2019 by Raible and SERT guards to cuff up. She was then taken to a strip cell for allegedly possessing a pen that she had used to write grievances. Once in the cell, Raible shot her with six pellets of pepper spray. Her cloths were covered with the spray and she was taken to a shower. Once she was soaked, she was returned to the cell and forced to put the contaminated clothing back on. After Diggs covered her cell door window, she was placed in a restraint chair by Raible and another sergeant. She spent the next eight hours in the chair while in her contaminated clothing.
The complaint alleged that Raible never tried to de-escalate any of the described situations, nor did he consult medical or mental health personnel before he administered the pepper spray. His forms of abuse were pervasive at ACJ in 2019:
• ACJ reported 720 use of force incidents which is twice the per capita rate of other Pennsylvania jails.
• Restraint chairs were used on 339 prisoners that year, a rate that is three times more frequent than other jails.
• Guards used Tasers or stun guns 146 times, which was half of the total uses of Tasers or stun guns in all 67 of Pennsylvania’s jails.
• ACJ guards used chemical agents on detainees 122 times.
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Related legal case
Walker v. Raible
|Cite||Case No. 2:20-cv-1868|