Background
Akeem Muhammad, a Florida state prisoner, sued correctional officer Boyce Turner under the Civil Rights Act for using excessive force on May ninth, two thousand and nineteen. Muhammad alleged that Turner violently taked him and applied a pain compliance technique after Muhammad filed a grievance against prison staff. The district court granted summary judgment to Turner, finding the security video contradicted Muhammad’s account.
The court’s reasoning
The Eleventh Circuit held that the security video was ambiguous due to obstructed views and poor audio, requiring the court to view the evidence in the light most favorable to the non-moving party. The court found that a reasonable jury could conclude the officer had no penological need to use force against a handcuffed, non-resistant inmate. The court further determined that the officer’s actions, including a violent takedown and prolonged pain compliance, could be found to be malicious and sadistic rather than a good-faith effort to maintain discipline.
we conclude the video does not clearly or blatantly contradict Muhammad’s version of events, and genuine issues of material fact exist that preclude summary judgment for Officer Turner.
What it means going forward
The case is remanded for trial, allowing the jury to determine whether the officer’s use of force violated the Eighth Amendment and whether the officer is entitled to qualified immunity.