Maldonado v. Brock

CourtDistrict Court, E.D. Texas
DecidedJuly 14, 2020
Docket5:17-cv-00157
StatusUnknown

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

Bluebook
Maldonado v. Brock, (E.D. Tex. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TEXARKANA DIVISION

PHILLIP MALDONADO, § § Plaintiff, § CIVIL ACTION NO. 5:17-CV-00157-RWS § v. § § JERRY L BROCK, § § Defendant. § §

ORDER Plaintiff Phillip Maldonado, a prisoner of the Texas Department of Criminal Justice, sued various defendants under 42 U.S.C. § 1983, alleging constitutional violations. This Court referred the case to the United States Magistrate Judge, who recommended Plaintiff’s claims against Sergeant Jerry Brock be dismissed with prejudice.1 Docket No. 77. Plaintiff objected to the Magistrate Judge’s recommendation. Docket No. 79. For the following reason, those objections are OVERRULED, and the Magistrate Judge’s recommendation is ADOPTED. I. Background Plaintiff claims that, on July 4, 2016, Sgt. Brock was summoned to the housing area because inmates, including Plaintiff, were outside their designated section of the facility. Sgt. Brock escorted Plaintiff back to the appropriate section, placed plaintiff in his cell and asked for Plaintiff’s identification (ID) card. Plaintiff replied that Sgt. Brock could see what cell and bunk he was in and could get that information off the pod roster. Sgt. Brock stated that, if Plaintiff did not provide his ID, then Brock would lock Plaintiff up.

1 Previously, the claims against all other defendants were dismissed without prejudice. Docket No. 59. According to Plaintiff, he exited the cell, turned around, placed his hands behind his back and was cuffed by Sgt. Brock. After walking a few steps, Plaintiff states he decided it was not worth going to lockup. Plaintiff then stopped and turned around, attempting to tell his cellmate to slide his ID under the door. But he was prevented from doing so, Plaintiff contends, because Sgt. Brock immediately swept his feet out from under him, slamming Plaintiff in the floor face first. As a result, Plaintiff states he fractured a bone in his face. After the use of force, Plaintiff asserts Sgt. Brock wrote a disciplinary case that alleged

Plaintiff had been ordered to stop pulling away and refused to comply with the order. Captain Gooden ran the disciplinary case without Plaintiff being present and falsely stated that Plaintiff was off the unit when, in fact, he was not. Plaintiff states this disciplinary case was overturned on appeal. II. Sgt. Brock’s Motion for Summary Judgment Sgt. Brock moved for summary judgment, offering his own version of the events. He claimed that he asked Plaintiff for his ID card, but Plaintiff refused. He put Plaintiff in hand restraints and attempted to escort him to the Eight Building holding cell. After the escort began, Sgt. Brock stated Plaintiff tried to pull away. Sgt. Brock stated he maintained his hold and told Plaintiff the minimum amount of force necessary to gain compliance would be used if he did not stop pulling away.

According to Sgt. Brock, Plaintiff complied and began walking, but tried to pull away again a few steps later. Sgt. Brock stated that he gave Plaintiff a second order and again explained the consequences of failing to comply. Plaintiff briefly complied, but then pulled away a third time. Sgt. Brock stated he used a leg sweep and applied downward pressure to bring Plaintiff to the ground. Other officers came to the scene, and Plaintiff was taken to the medical department. Sgt. Brock acknowledges that Plaintiff suffered a fractured orbital bone requiring surgery but argues the force was used in a good faith effort to restore discipline in response to Plaintiff’s repeated Page 2 of 8 non-compliance. To Sgt. Brock, his use of force was neither malicious nor sadistic. Sgt. Brock invoked his entitlement to qualified immunity. III. The Summary Judgment Evidence The Defendants submitted a use of force report, which concluded the use of force was justified, and Plaintiff’s medical records, which showed Plaintiff had a fractured orbital bone and underwent surgery on July 19, 2016. The Defendants also submitted a surveillance video showing the incident, which contradicts

Plaintiff’s view of the events. This video opens with Sgt. Brock standing behind Plaintiff in front of his cell, apparently securing the handcuffs. The two men take a quarter turn to their left, bringing them to face the camera directly. They are at the far side of the dayroom from where the camera is located. Plaintiff starts to walk toward the camera but veers to his left, circling around Sgt. Brock. He takes five steps and stops. Sgt. Brock then steps behind him, and they walk through the dayroom toward the camera. As they approach the bottom of the frame, Plaintiff pulls away from Sgt. Brock heading toward his right. Sgt. Brock pulls him back and gestures toward a doorway in the bottom right corner of the screen. They turn around so their backs are to the camera, facing back the way they came. Plaintiff can be seen pulling away from Sgt. Brock. He takes about four or five steps back

the way he came, towards his cell on the other side of the dayroom. Sgt. Brock follows just behind him, with his left arm trying to hold Plaintiff’s right arm. On Plaintiff’s fifth step toward his cell, Sgt. Brock uses his right leg to trip Plaintiff, taking him to the floor. He remains on top of Plaintiff, holding him down, until other officers arrive. Medical personnel come to the scene and Plaintiff is placed on a gurney for transport to the infirmary.

Page 3 of 8 IV. The Magistrate Judge’s Report The Magistrate Judge reviewed the summary judgment evidence, including the video, and issued a report recommending Sgt. Brock’s motion for summary judgment be granted. The Magistrate Judge set out the law governing use of force claims, stating the core judicial inquiry was whether the force was used in a good-faith effort to restore discipline or maliciously and sadistically for the very purpose of causing harm. Wilkins v. Gaddy, 559 U.S. 34, 35 (2010). In making this determination, the Fifth Circuit has identified five factors to be considered: (1) the extent of the injury suffered; (2)

the need for the application of force; (3) the relationship between the need and the amount of force used; (4) the threat reasonably perceived by the responsible officials; and (5) any efforts made to temper the severity of a forceful response. Baldwin v. Stalder, 137 F.3d 836, 839 (5th Cir. 1998); Hudson v. McMillian, 962 F.2d 522, 523 (5th Cir. 1992). These are commonly referred to as the “Hudson factors.” See, e.g., Baldwin, 137 F.3d at 838–39. The Magistrate Judge analyzed each of these factors separately. While the first factor clearly weighed in Plaintiff’s favor, the Magistrate Judge determined that the second and fourth factors weighed in Sgt. Brock’s favor and that the third and fifth factors were inconclusive. In reviewing the central question of whether the force was used in a good faith effort to restore discipline or

maliciously and sadistically for the very purpose of causing harm, the Magistrate Judge concluded as follows: The surveillance video shows Sgt. Brock did not act maliciously or sadistically for the very purpose of causing harm. Rather, he was faced with a recalcitrant inmate who resisted his attempts to remove him from the housing area by continually trying to pull away and trying to move in a different direction. See, e.g., Williams v. Valenti, 432 F.App’x 298, 2011 WL 2650883 (5th Cir., July 7, 2011) (use of force not malicious or sadistic where inmate was belligerent and pulled away when officer grasped his arm); Waddleton [v. Rodriguez, 750 F.App’x 248 (5th Cir.

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Related

Wilkins v. Gaddy
559 U.S. 34 (Supreme Court, 2010)
Baldwin v. Stalder
137 F.3d 836 (Fifth Circuit, 1998)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Keith J. Hudson v. Jack McMillian Cso III
962 F.2d 522 (Fifth Circuit, 1992)
Soto v. Dickey
744 F.2d 1260 (Seventh Circuit, 1984)

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