Henderson v. Frierson

CourtDistrict Court, D. South Carolina
DecidedDecember 23, 2024
Docket4:23-cv-03022
StatusUnknown

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

Bluebook
Henderson v. Frierson, (D.S.C. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION

Aryee Henderson, Case No. 4:23-cv-03022-SAL

Plaintiff,

v. ORDER Sgt. Frierson,

Defendant.

The matter is before the court on two Reports and Recommendations issued by United States Magistrate Judge Thomas E. Rogers (together, the “Reports”): (1) the magistrate judge’s June 21, 2024, Report and Recommendation recommending the court deny plaintiff Aryee Henderson’s two motions for a temporary restraining order and preliminary injunction (the “TRO Report”), ECF No. 82; and (2) the magistrate judge’s October 23, 2024 Report and Recommendation recommending the court grant defendant Sergeant Jerrell Frierson’s (“Sgt. Frierson”) motion for summary judgment (the “Summary Judgment Report”), ECF No. 118. For the reasons below, the court adopts both Reports in full. BACKGROUND Henderson is currently incarcerated with the South Carolina Department of Corrections and housed at the Lee Correctional Institution (“Lee CI”). One day in late-January 2022, Henderson began to stuff tissue in the padlock at the flap of his cell door. [See Am. Compl., ECF No. 61-1 ¶ 52.] Sgt. Frierson approached Henderson’s cell door while Henderson stuffed tissue in the padlock and directed him to “get off the flap.” Id. ¶ 55. The parties dispute whether Henderson stopped stuffing the padlock but, in any event, Sgt. Frierson testified that he walked away from Henderson’s cell to retrieve a tool to unjam the padlock. [ECF No. 105-4, Sgt. Frierson Decl. ¶ 5.] When Sgt. Frierson returned to Henderson’s cell, he saw Henderson continue to, in his view, “sabotage” the lock. Id.; see also Am. Compl. ¶ 59 (alleging Henderson continued resumed stuffing the padlock after Sgt. Frierson walked away). Sgt. Frierson then “administered a short

burst of chemical munition toward” Henderson and directed Henderson to release the flap and stop jamming the lock. Sgt. Frierson Decl. ¶ 7. Henderson alleges Sgt. Frierson did not warn him about the spray or direct him to stop , and he further alleges that he would have complied with such a warning. Am. Compl. ¶¶ 62, 65. Henderson also maintains he was not a threat to himself or to anyone else at the time Sgt. Frierson sprayed him. Id. ¶ 65. Sgt. Frierson allegedly did not

utilize any de-escalation tactics before spraying Henderson. Id. ¶ 77. Henderson alleges the spraying occurred directly in his face, causing the spray to get in his mouth, nose, eyes, ears, hair, and neck. Id. ¶ 69. Henderson’s face, neck, ears, nose, and mouth burned all night “like it was on fire”; his nose ran with mucus all night; and he was blinded and couldn’t see for hours. Id. ¶¶ 70–72. He also alleges the pepper spray caused him to suffer from loss of breath (for at least an hour), humiliation, anxiety, restlessness, lack of sleep due to an

extreme burning sensation, loss of appetite, homicidal ideations, psychological and emotional distress, and mental anguish. Id. ¶ 73. A nurse “came to see” Henderson but did not give him anything to wipe off the paper spray or anything for his pain, and nobody took Henderson out of the cell to decontaminate in the shower. Id. ¶¶ 74–75. Henderson sued Sgt. Frierson for violating his Eighth Amendment rights after filing Step

1 and Step 2 Grievances. [See generally Am. Compl.; see also ECF No. 61-2 at 3–6.] He seeks an award of compensatory damages in the amount of $150,000; punitive damages in the amount of $350,000; and to be placed within the Columbia Regional Care Center. Am. Compl. at 6. While the litigation was pending, Henderson moved twice for a temporary restraining order and preliminary injunction because he was denied access to a law library, legal supplies, and the “U.S. Postal Mailbox.” [See generally ECF Nos. 71 and 76.] The magistrate judge issued the TRO

Report on June 21, 2024, recommending the court deny Henderson’s requests for injunctive relief. [See generally ECF No. 82.] Henderson objected to the TRO Report on July 17, 2024. [See generally ECF No. 96.] Sgt. Frierson later moved for summary judgment, arguing: (1) Henderson failed to exhaust his administrative remedies, so his claims were subject to dismissal under the Prison Litigation

Reform Act (PLRA); (2) Henderson’s claims against Sgt. Frierson in his official capacity are barred by the Eleventh Amendment; (3) there is no evidence to support any claim under 42 U.S.C. § 1983; (4) there is no evidence to support any claim of excessive force or any other claim under the Eight Amendment or for violations of the United States Constitution; (5) alternatively, Sgt. Frierson is entitled to qualified immunity under Harlow v. Fitzgerald; (6) Henderson is not entitled to punitive damages; and (7) any purported state law claims are barred by the South Carolina Tort

Claims Act. [See generally ECF No. 105.] The magistrate judge granted Henderson an extension to respond to Sgt. Frierson’s summary judgment motion, but Henderson never filed any response. [See ECF No. 118 at 1.] The magistrate judge issued the Summary Judgment Report on October 23, 2024, recommending the court grant Sgt. Frierson’s motion for summary judgment and dismiss Henderson’s case. [See generally ECF No. 118.]

Attached to the Summary Judgment Report was a notice advising Henderson of the procedures and requirements for filing objections to the Summary Judgment Report and the serious consequences if he failed to do so. [ECF No. 118-1.] The notices specifically warned Henderson that if he did not timely file an objection to the Summary Judgment Report then the court “need not conduct a de novo review[] but instead must ‘only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.’” Id. (quoting Diamond v. Colonial

Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005)). The notice also warned Henderson his “[f]ailure to timely file specific written objections to [the Summary Judgment Report] will result in waiver of the right to appeal from a judgment of the District Court based upon such Recommendation.” Id. (internal citations omitted). Henderson did not object or otherwise respond to the Summary Judgment Report, and the time to do so has expired.

REVIEW OF A MAGISTRATE JUDGE’S REPORT

The magistrate judge makes only a recommendation to this court. The recommendation has no presumptive weight, and the responsibility to make a final determination remains with this court. See Mathews v. Weber, 423 U.S. 261, 270–71 (1976). In response to a recommendation, any party may serve and file written objections. Elijah v. Dunbar, 66 F.4th 454, 459 (4th Cir. 2023) (citing 28 U.S.C. § 636(b)(1) and Fed. R. Civ. P. 72(b)(3)). The district court then makes a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made. Id. To trigger de novo review, an objecting party must object with sufficient specificity to reasonably alert the district court of the true ground for the objection. Id. (quoting United States v. Midgette, 478 F.3d 616, 622 (4th Cir. 2007)).

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Henderson v. Frierson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henderson-v-frierson-scd-2024.