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After Second Circuit Rules in His Favor, Connecticut Prisoner Required to Exercise in Full Restraints for Six Months Takes $100,000 Settlement

by Matt Clarke

After a federal appeals court vacated a district court’s judgment in favor of Connecticut prison officials, they settled for $100,000 with a prisoner forced to exercise in full restraints for six months a decade ago.

On January 27, 2021, the U.S. Court of Appeals for the Second Circuit held that a warden was personally involved in the decision requiring the prisoner to conduct his outdoor exercise in full restraints for six months, vacating a judgment as a matter of law granted by the district court in defendants’ favor, which they had sought following a jury verdict awarding $750,000 in damages to the prisoner plaintiff.

The ruling came almost a decade after the case was first filed in October 2011, by the prisoner, M. A. Edwards, who was transferred to Connecticut’s now-shuttered maximum-security Northern Correctional Institution in Somers after assaulting a guard at a lower-security state prison. There he was held in punitive segregation about a month and then transferred to Phase I Administrative segregation, both of which featured the most restrictive conditions in the prison.

Ordinarily, Phase I prisoners were held in Unit One, which had outdoor recreation yards equipped with small enclosures with trap doors that allowed guards to remove a prisoner’s restraints while physically separated from him, so that the prisoner could exercise without restraints.

Due to a lack of space in Unit One, however, Edwards was housed in Unit Three for a total of six months, until he was re-classified to Phase II. Phase I prisoners being held in Unit Three were supposed to be rotated into Unit One after a week or two so they could exercise without restraints because Unit Three yards lacked the small enclosures necessary to remove them.

But Edwards was not rotated out of Unit Three for six months. He filed a pro se federal civil rights action pursuant to 42 U.S.C. § 1983 in U.S. District Court for the District of Connecticut against several high-ranking supervisory officials. Defendants filed a motion for summary judgment, which the court granted after finding no clearly established right for prisoners to exercise without restraints. On appeal, the Second Circuit reversed that decision, and New Paltz, New York, attorney Stephen Bergstein II was appointed pro bono counsel to represent Edwards.

On remand to the District Court, Edwards testified during a jury trial that he could only shuffle about the outdoor recreation yard when restrained in handcuffs and leg irons with a chain connecting them. He admitted being able to exercise unrestrained in his 7-by-12-foot cell, but this was limited to little more than push-ups and sit-ups because the bunk, desk, chair, footlocker, sink and toilet occupied much of the floor space.

Defendant Warden Angel Quiros testified that he endorsed the policy requiring Phase I overflow prisoners housed in Unit Three to exercise in full restraints. He said that he kept a close tab on all Phase I prisoners—especially those in Unit Three. The jury then returned a verdict of $500,000 in compensatory damages and $250,000 in punitive damages against Quiros, but it found in favor of his co-defendant, Deputy Warden Lauren Powers Powers.

Quiros filed a motion for judgment as a matter of law, which the district court granted, finding insufficient evidence of Quiros’ personal involvement in the decision to require Edwards to exercise in full restraints. Edwards again appealed.

The Second Circuit held then that the jury had “abundant circumstantial evidence” to reasonably infer Quiros’ actual knowledge of Edwards’ recreation status, including Quiros’ own testimony. Further, safety concerns could not be used to excuse the lack of exercise, the Court said. Therefore, it could not find that the jury verdict was erroneous as a matter of law. The District Court’s judgment was vacated and the case remanded for further proceedings. See: Edwards v. Quiros, 986 F.3d 187 (2d Cir. 2021).

The case settled on remand on September 21, 2021, with the state agreeing to pay Edwards $100,000, of which $16,366.66 was disbursed to state Child Support Services to satisfy Edwards’ obligation, and another $25,000 was split evenly between his attorneys, Bernstein and Christopher M. Licari of the Branford firm of Licari Walsh & Sklaver. The remaining balance of $58,633.34 was also given to Licari Walsh & Sklaver to hold on Edwards’ behalf. See: Edwards v. Arnone, USDC (D.Conn.), Case No. 3:11-cv-01537-SRU. 

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Related legal cases

Edwards v. Quiros

Edwards v. Arnone