$50,000 for Excessive Force Claim by Maryland Prisoner Who Used to Be a Guard
On March 19, 2025, an agreement was reached paying $50,000 to a Maryland prisoner—who is also a former Baltimore jailer—to settle his claim that he was subjected to excessive force by a guard at Western Correctional Institution (WCI). The agreement settled two suits that prisoner Jeffrey Corporal filed over the incident, one against WCI guard Lt. James Smith and the other against WCI Warden Ronald Weber and other officials with the state Department of Public Safety and Correctional Services (DPSCS).
Corporal, now 39, was a guard at the Baltimore City Jail before he was convicted in August 2007 of participating in the armed robbery of a convenience store clerk; as PLN reported, that left him fearful of assault from fellow prisoners, so he often refused to accept assigned cellmates at WCI. When guards tried to uncuff a new cellmate in December 2019 and Corporal objected, they maced his cell and forced him to the hallway floor, where he was lying compliantly when Smith dragged him to a property room and sucker-punched him, finishing him off with a 50-second blast of mace, the prisoner said. [See: PLN, Nov. 2022, p.20.]
Corporal filed his pro se complaints in the federal court for the District of Maryland, which in September 2021 denied qualified immunity to Smith; Corporal was also appointed counsel, whose discovery request turned up previously undisclosed surveillance video of the incident that prompted him to add defendants and claims in a second amended complaint, which the district court also allowed in October 2022. See: Jeffrey v. Smith, 2021 U.S. Dist. LEXIS 167016 (D. Md. 2021); and Corporal v. Smith, 2022 U.S. Dist. LEXIS 184499 (D. Md. 2022).
The first of those rulings also dismissed a related challenge that Corporal filed to his conditions of confinement, claiming that Defendant prison officials manipulated his access to the mail and to the prison law library in such a way as to prevent him from meeting filing deadlines at the DPSCS Inmate Grievance Office (IGO) and state circuit court. Corporal appealed that part of the ruling, which the U.S. Court of Appeals for the Fourth Circuit reversed on July 19, 2023.
As the Court recalled, “Defendants used a private mail system for delivering IGO decisions,” which Corporal blamed when he “received notification of the IGO’s dismissal of this grievance after most of his time to petition the relevant state circuit court for review had expired.” Efforts to hurry a petition for review before that window closed were further frustrated, he said “by Defendants’ policy for operating the prison library,” ultimately preventing him from “seeking review of the dismissal of the grievance.” The Court found error in dismissal of these allegations because they “were sufficient to plausibly state a claim for relief.”The ruling also affirmed dismissal of Corporal’s challenge to a procedural error made by Defendants at the district court, an error that the appellate Court called harmless. See: Corporal v. Weber, 2023 U.S. App. LEXIS 18324 (4th Cir.).
On remand, the district court denied cross-motions for summary judgment, saying that both parties needed to develop their arguments with additional briefing before it could take up the issues. However, the text of the order, which was issued on November 22, 2023, seemed to weigh more heavily against Defendants; they were called to defend slow-walking Corporal’s grievance, while he was directed merely to clear up confusion about exactly which grievance was at issue. See: Corporal v. Weber, 2023 U.S. Dist. LEXIS 209030 (D. Md.).
On January 8, 2024, the Supreme Court of the U.S. declined to issue a writ of certiorari to hear Corporal’s challenge to the Fourth Circuit’s refusal to hold Defendants to task for their procedural error. See: Corporal v. Weber, 144 S. Ct. 584 (2024). Defendants then filed one more motion to dismiss, but the district court denied it on April 4, 2024. After that, the parties proceeded to reach their settlement agreement, which included fees and costs for the prisoner’s counsel, attorney Donald P. Salzman of Skadden Arps Slate Meagher and Flom LLP in Washington, D.C. See: Corporal v. Smith, USDC (D. Md.), Case No. 8:20-cv-01193; and Corporal v. Weber, USDC (D. Md.), Case No. 1:20-cv-02681.
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Related legal case
Corporal v. Weber
| Year | 2025 |
|---|---|
| Cite | USDC (D. Md.), Case No. 1:20- cv-02681 |
| Level | District Court |