Collins v. Chatman

CourtDistrict Court, W.D. Wisconsin
DecidedApril 30, 2024
Docket3:23-cv-00030
StatusUnknown

This text of Collins v. Chatman (Collins v. Chatman) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Collins v. Chatman, (W.D. Wis. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

MAURICE COLLINS,

Plaintiff, OPINION and ORDER v.

23-cv-30-jdp LT. CHATMAN,

Defendant.

Plaintiff Maurice Collins, without counsel, alleges that defendant Lt. Chatman used excessive force on him by tasing him even though he was restrained and not resisting being force-fed. Collins, who is incarcerated at Columbia Correctional Institution (CCI), brings an excessive force claim under the Eighth Amendment. Chatman moves for summary judgment. Dkt. 18. Chatman contends that Collins, who was on a hunger strike, resisted nurses’ efforts to tube-feed him pursuant to a court order, and that he tased him in a good-faith effort to gain his compliance with that order. Chatman adds that he tased Collins only after he and the nurses repeatedly failed to persuade him to allow the tube feeding, and that video footage corroborates his account of the incident. Collins contends that he couldn’t resist the nurses’ efforts to insert the feeding tube because he was restrained, and that Chatman tased him out of frustration because the nurses’ efforts were unsuccessful. Collins adds that Chatman accused him of resisting the nurses’ efforts as an excuse to tase him. Video of the incident shows that Collins initially attempted to avoid the tube feeding and engaged in other defiant behavior. The evidence also establishes that the nurses who attempted to conduct the tube feeding told Chatman about Collins’s resistance. Chatman ultimately deployed his taser for approximately five seconds, but only after making repeated, non-forceful, efforts to persuade Collins to comply with the nurses’ efforts. The only reasonable conclusion is that Chatman tased Collins in a good-faith effort to gain his compliance with a medically necessary court order to tube feed him. I will grant Chatman’s motion.

UNDISPUTED FACTS The following facts are undisputed except where noted. At the time of the incident, Chatman, the sole defendant here, was employed as a correctional captain at CCI. Collins was housed at CCI in the restrictive housing unit (RHU). Prisoners in the RHU typically present a high-security risk, including self-injury. Collins was engaging in a hunger strike and was being routinely tube-fed pursuant to a Wisconsin circuit court order determining that force-feeding him was medically necessary and justified to protect his health. CCI staff were required to follow the court order.

On the day of the incident, Collins was on temporary lockup status for disobeying orders and disruptive conduct. At around 5:00 p.m., Collins initially refused to leave his cell for his scheduled tube feeding. Lt. Bortz informed Chatman, who then assembled a “pad-subduing” team consisting of five correctional officers, including Heriberto Ruiz. When the pad-subduing team went to Collins’s cell, he complied with Chatman’s order to exit and submit to restraints. The team placed Collins in a restraint chair and wheeled him to the exam room to start his court-ordered tube feeding. It is standard procedure to restrain prisoners who are removed from the RHU for court-ordered tube feedings.

Nurse Johnson attempted to put the feeding tube in Collins’s nose, but he moved his head away from her. Dkt. 21-1 (Def.’s First Video 12:21, 12:23–38). Chatman directed Ruiz to secure Collins’s head in a compliance hold, and Ruiz tilted Collins’s head back and held it against his chest. The parties dispute the precise placement of Ruiz’s hands on Collins’s face, but that dispute is immaterial. Johnson continued without success for several minutes, and she accused Collins of resisting her efforts. See id. (14:22–27). Shortly thereafter, Ruiz stated that

Collins was blocking the tube, upon which Chatman held a taser to his leg without firing it and ordered him to stop resisting. Collins repeatedly threatened to bite Ruiz’s hands and fingers, and repeatedly stated that the group would be there until 5:00 a.m. See, e.g., Dkt. 21-1 (Def.’s First Video 14:37; 16:42–47, 16:58; 17:19, 17:46–51, 17:59). After several unsuccessful attempts to insert the tube, Johnson called nurse Holmen for assistance. Collins repeatedly moved his head away when Holmen tried to insert the tube, after which Ruiz put him in a compliance hold. Dkt. 21-2 (Def.’s Second Video 0:24–32). Neither Holmen nor Johnson managed to insert the tube, and they both accused Collins of obstructing

their efforts. Id. (1:52, 2:32, 4:50, 5:07). Chatman then deployed his taser, holding it to Collins’s leg and using it as a drive stun for approximately five seconds. Id. (5:09–5:14); Dkt. 22 ¶¶ 31–33. Johnson then continued to insert the tube without success for two minutes, after which she told Chatman that she needed more supplies. Chatman directed officers to transport Collins to the programming area in the meantime. The officers returned Collins to the exam room approximately 20 minutes later. Johnson managed to insert the tube without incident, and Collins completed his scheduled feeding.

The parties dispute whether Collins resisted insertion of the feeding tube when the nurses were trying to insert it, and the video doesn’t conclusively answer that question. The video shows Collins violently coughing, gagging, and breathing in a heavily labored manner. At varying times, Johnson, Holmen, Chatman, and Ruiz can be heard saying that Collins was resisting the nurses’ efforts to insert the feeding tube by creating tension in his throat and refusing to swallow. By contrast, Collins contends that the nurses simply couldn’t manage to get the tube down his throat, and he suggests that Ruiz’s placement of his hand around the

bridge of his nose played a role in that result. I will discuss additional facts as they become relevant to the analysis.

ANALYSIS To establish a claim for excessive force based on a prison official’s use of force, the prisoner must show that the official applied the force maliciously and sadistically to cause harm rather than in a good-faith effort to maintain or restore discipline. Hudson v. McMillian, 503 U.S. 1, 6 (1992). Even if a prison official’s use of force causes a prisoner objectively serious injury, the conduct violates the Eighth Amendment only if the official acts maliciously and

sadistically for the purpose of harming the prisoner. Harper v. Albert, 400 F.3d 1052, 1065 (7th Cir. 2005). To make this determination, courts should consider all the circumstances, and may consider “the need for force, the amount of force used, the threat reasonably perceived by the officer, efforts made to temper the severity of the force, and the extent of the injury caused by the force.” See Lewis v. Downey, 581 F.3d 467, 477 (7th Cir. 2009); Fed. Civ. Jury Instr. 7th Cir. 7.18 (2017). In many circumstances, such as when prison officials face aggression, disruption, or physical threats from prisoners, “compelling compliance with an order is a valid penological

justification for use of a taser.” Lewis, 581 F.3d at 477. Put differently, a prison official’s use of a taser in these and other circumstances can be a “good faith effort to maintain or restore discipline within the [prison].” See Forrest v. Prine, 620 F.3d 739, 747 (7th Cir. 2010); cf. Lewis, 581 F.3d at 478 (recognizing that “any number of scenarios” could justify the use of a taser in the penal context). No reasonable juror could conclude that Chatman tased Collins maliciously and

sadistically to harm him.

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Related

Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Forrest v. Prine
620 F.3d 739 (Seventh Circuit, 2010)
Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
George Harper and Robert Padilla v. Lieutenant Albert
400 F.3d 1052 (Seventh Circuit, 2005)
Berrell Freeman v. Gerald A. Berge
441 F.3d 543 (Seventh Circuit, 2006)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Lewis v. Downey
581 F.3d 467 (Seventh Circuit, 2009)

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Collins v. Chatman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/collins-v-chatman-wiwd-2024.