U.S. District Court: RESTRAINTS USE OF FORCE.

PositionPrisoners and prisons - Brief Article

Jackson v. Johnson, 118 F.Supp.2d 278 CN.D.N.Y. 2000). Representatives of a juvenile who was incarcerated in a youth center sought damages for injuries sustained by the juvenile when he was subjected to a physical restraint technique (PRT). The district court dismissed the defendants' motions for summary judgment, finding that there were fact issues as to whether aides applied excessive force in violation of the juvenile's substantive due process rights. The court held that the Eighth Amendment did not apply to incarcerated juveniles, but rather that the appropriate constitutional standard for evaluating the treatment of an adjudicated juvenile delinquent is the substantive due process guarantee of the Fourteenth Amendment. The court denied qualified immunity for a nurse at the center, holding that it was not objectively reasonable for her to conclude that the juvenile was faking injury in view of his unresponsiveness and general physical condition.

A 220-pound aide had initiated a PRT on the 145-pound juvenile and was assisted by a 250-pound coworker. The PRT was applied for approximately ten minutes before the officer of the day...

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