U.S. Appeals Court: SCREENING.

• Position: Brief Article

Grayson v. Peed, 195 F.3d 692 (4th Cir. 1999). The administrator for the estate of a deceased detainee sued officers and county officials under [sections] 1983 asserting constitutional violations, negligence, gross negligence, negligent training and negligent supervision. The district court granted summary judgment or the defendants on all [sections] 1983 claims and declined to assume supplemental jurisdiction over state law claims. The appeals court affirmed. The detainee had been arrested and transported to the county detention center and the following day was declared brain dead. During his booking the detainee was acting irrationally, his speech was slurred, and he kept repeating in an intoxicated manner "I can't believe this is all over a traffic ticket." He was then taken to a cell and strip searched, but at the conclusion of the search attempted to crawl out of the cell and a struggle ensued. Officers used pepper spray to subdue him. Early the next morning the detainee began acting belligerent again. H e resisted being moved to another cell and a five-man cell extraction team pinned him face down. During the struggle he was sprayed with pepper spray and he was punched several times. Once restrained, he...