Minnesota Supreme Court: Prisoner Abused with Overtight Handcuffs Need Only Show Deliberate Indifference, Not Malicious Intent
by Matthew Clark
On December 14, 2022, the Minnesota Supreme Court took up a state prisoner’s claim that he was left with permanent nerve damage from restraints guards misused during a routine medical transport. The Court held that the proper standard to apply is whether the allegations show deliberate indifference, not intent to cause harm.
Christopher Welters was being transported from the Minnesota Correctional Facility (MCF) at Stillwater to MCF Oak Park Heights for scheduled outpatient medical clinic appointments on July 31, 2017. Guards Cornelius Emily and Ernest Rhoney put him in full restraints for the trip, per policy of the state Department of Corrections (DOC). But Welters noticed right away that his handcuffs were too tight.
“Oh, it’s only a 15-minute drive,” Rhoney allegedly told him, “it’ll be all right.”
But it wasn’t “all right.” In fact, as Welters entered the transport van, he felt the restraints “click” even tighter – meaning the device was not double-locked, in violation of DOC policy. When he complained, Rhoney pushed on the handcuff to check, and it clicked tighter again. He agreed the device was not double-locked. But he did nothing to fix the problem.
By the time he arrived at the clinic, Welters hands were numb. Both he and a nurse asked clinic guards to loosen the cuffs. In response they went looking for the Stillwater guards who transported Welters. Meanwhile, he was given anesthesia and underwent endoscopy. When he awoke, Welters couldn’t feel his hands at all. By the time he was back at Stillwater – after 3-1/2 hours in overtight restraints – his hands were blue.
As he lost function in his hands, Welters “struggled to hold a toothbrush,” according to the complaint he later filed. He was forced “on medical leave from prison work.” Ultimately, he “required carpal tunnel surgery in both wrists.”
Welters filed suit against DOC and its guards in state court for Washington County. Proceeding under 42 U.S.C. § 1983, he accused them of deliberate indifference to his serious medical need, in violation of his Eighth Amendment guarantee of freedom from cruel and unusual punishment. Defendants argued that was the wrong standard – that Welters needed to prove the guards acted with malicious intent. Alternatively, they claimed qualified immunity (QI) – presumably because there was no case law specifically stating that a prisoner had a right not to be transported in restraints so tight that he was left with injuries requiring surgery.
The district court never got to the issue of QI; it agreed with Defendants that Welters needed but failed to show malicious intent, pointing to Hudson v. McMillan, 503 U.S. 1 (1992). So Defendants were granted summary judgment. The Court of Appeals reversed that decision. Quoting Hope v. Pelzer, 536 U.S. 730 (2002), it said that the guards subjected Welters “to a substantial risk of physical harm” and “unnecessary pain.” The appeals court also said they were not entitled to QI because case law clearly established that the constitution “forbids the inhumane use of restraints that cause injury to prisoners.”
On appeal, Minneapolis attorney Zorislav R. Leyderman represented Welters before the state Supreme Court, which began with the question: Which standard properly applies, malicious intent or deliberate indifference? Whereas Hudson is the proper standard to apply when guards attempt to restore order during prison disruptions, the Court allowed, both guards testified that the prison transport was routine. Failing to double-lock restraints and keeping a compliant prisoner in restrains after arrival violated prison policy, too. Therefore, the proper standard was the one laid out in Hope: deliberate indifference.
The Court went on to add, pursuant to Farmer v. Brennan, 511U.S. 825 (1994), that the guards were not entitled to QI because they had actual knowledge of an objective and substantial risk to Walters’s health or safety and disregarded it. Moreover, Hope had already established a prisoner’s right not to be subjected to pain and injury using improper restraint devices – further defeating their QI claims. Therefore, the appellate court decision was affirmed. See: Welters v. Minn. Dep’t of Corr., 982 N.W.2d 457 (Minn. 2022).