$1.3 Million for Massachusetts Prisoner Stabbed by Guard in Connecticut Lockup
On October 21, 2024, after a trial in the U.S. District Court for the District of Connecticut, judgment was entered awarding former state prisoner Justin C. Mustafa $1.3 million on his claim that he was repeatedly stabbed by Defendant state prison guard Christopher Byars.
In December 2018, according to Mustafa’s pro se complaint, he was transferred from Souza-Barnowski Correctional Center in Massachusetts to Connecticut’s MacDougall-Walker Correctional Institute (MWCI). There on May 25, 2019, Byars brought Mustafa a “special food tray,” which the prisoner believed that the guard had contaminated. In an effort to gain other staff members’ attention, Mustafa said, he “h[e]ld the wicket” closed on the cell door to prevent Byars from serving the tray. Byars, in response, placed a key between his knuckles and repeatedly punched Mustafa’s hand, stabbing it and puncturing one of the prisoner’s fingers. Because Byars then allegedly refused to call for a supervising lieutenant, Mustafa smeared blood on the cell door window to get medical attention.
Mustafa submitted a Level 1 grievance on June 6, 2019, but MacDougall staff did not collect grievances for 30 days and rejected it as “untimely.” In July of that year, Mustafa filed a Level 2 grievance appealing this rejection. Two months later, the Level 2 grievance was deemed “compromised” because the Level 1 grievance had been improperly declined. This permitted Mustafa to refile his Level 1 grievance within five days of his receipt of the Level 2 decision.
By that time, though, Mustafa had been returned to a prison in Massachusetts, so he did not refile the grievance in Connecticut. Instead he filed his suit in November 2019, alleging numerous claims against Byars and other Connecticut Department of Corrections (DOC) employees. Byars sought summary judgment dismissal, arguing that because Mustafa did not refile his Level 1 grievance, he had failed to exhaust his administrative remedies, in violation of the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e.
Citing the PLRA in its ruling on September 9, 2022, the district court noted that “[n]o action shall be brought with respect to prison conditions … by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” However, “failure to exhaust” is an affirmative defense, and the burden is on Defendants to prove that a Plaintiff failed to exhaust his claims before filing in court. Moreover, the exhaustion requirement may be excused if the remedy is not available in practice, even if it is “officially on the books,” in the words of Ross v. Blake, 578 U.S. 632 (2016).
The district court concluded that if Mustafa received the Level 2 disposition while still incarcerated in Connecticut, the grievance procedure would have been available to him and Byars would prevail on the “failure to exhaust” defense. However, if Mustafa received the Level 2 disposition after his return to Massachusetts, then the grievance procedure was opaque and unavailable to him because Connecticut’s A.D. 9.6 provided no instruction as to procedures for prisoners no longer in the custody of the state DOC. Because a dispute of material fact existed, summary judgment for Byars was inappropriate, the district court declared. See: Mustafa v. Stanley, 2022 U.S. Dist. LEXIS 163292 (D. Conn.).
The case then proceeded to trial, where the jury awarded Mustafa $500,000 in compensatory damages and $850,000 in punitive damages. By that point, Mustafa had picked up representation from attorneys Elliott B. Spector, Jared M. Alfin, Forest A. Noirot and Jeffrey O. McDonald of Hassett & George P.C. in Simsbury. See: Mustafa v. Stanley, No. 3:19-cv-01780-VAB (D. Conn. 2024).
Mustafa had also brought a claim for use of excessive force against another Connecticut guard named Pelletier, which the district court also greenlighted. However, that portion of its judgment was reversed by the U.S. Court of Appeals for the Second Circuit on November 14, 2023, when it found that Pelletier was entitled to qualified immunity because it wasn’t clearly established that dousing a prisoner with a cup of juice was a violation of his civil rights. See: Mustafa v. Corr. Officer Pelletier, 2023 U.S. App. LEXIS 30197 (2d Cir.).
Equally frustrating, the Connecticut DOC apparently rewarded Byars’ costly, unlawful, violent, and atrocious behavior by promoting him to guard captain.
Meanwhile, surveillance video of the incident, which was played to jurors, remained under seal, even though neither party had requested it. The state chapter of the American Civil Liberties Union (ACLU) filed a motion to intervene in the case and compel release of the footage, which was partially granted on March 21, 2025, allowing the ACLU to view the tape. See: Mustafa v. Byars, 2025 U.S. Dist. LEXIS 52865 (D. Conn.).
Additional source: Middletown Press
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Related legal case
Mustafa v. Stanley
| Year | 2024 |
|---|---|
| Cite | Case No. 3:19-cv-01780 (D. Conn. 2024) |
| Level | District Court |
| Conclusion | Jury Verdict |