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Purposeful Exposure to Ultraviolet Light Warrants Denial of Qualified Immunity
On March 25, 2010, the U.S. Court of Appeals for the Eight Circuit affirmed in part a summary judgment denial is a 42U.S.C. §1983 suit that alleges Arkansas prison guards maliciously and out of retaliation exposed a prisoner to ultraviolet light.
Eric Williams filed suit after guards at Arkansas prison removed a protective shield over an ultraviolet lamp in Williams’ cell that was designed to ward off tuberculosis. Williams alleged that the guards removed the protective shield out of retaliation for comments one of Williams’ cellmates made during a search of Williams’ room.
The issue on appeal was whether the law was clearly established that the guards’ conduct was improper. The Eighth Circuit held that it was. “We do not believe that qualified immunity in this context hinges on the question of whether prior cases referenced the particular, technological manner in which force was applied,” the court wrote. What mattered was the “allegations of purpose fullness and retaliation,” the court concluded. The Judgment of the district court was accordingly affirmed in part.
See: Williams v. Jackson, 600 F. 3d 1007, (8th Cir. 2010).
Eric Williams filed suit after guards at Arkansas prison removed a protective shield over an ultraviolet lamp in Williams’ cell that was designed to ward off tuberculosis. Williams alleged that the guards removed the protective shield out of retaliation for comments one of Williams’ cellmates made during a search of Williams’ room.
The issue on appeal was whether the law was clearly established that the guards’ conduct was improper. The Eighth Circuit held that it was. “We do not believe that qualified immunity in this context hinges on the question of whether prior cases referenced the particular, technological manner in which force was applied,” the court wrote. What mattered was the “allegations of purpose fullness and retaliation,” the court concluded. The Judgment of the district court was accordingly affirmed in part.
See: Williams v. Jackson, 600 F. 3d 1007, (8th Cir. 2010).
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Related legal case
Williams v. Jackson
| Year | 2010 |
|---|---|
| Cite | 600 F. 3d 1007, (8th Cir. 2010) |
| Level | Court of Appeals |
| Injunction Status | N/A |