Underwood v. Barrett

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The First Circuit vacated the district court's denial of prison officials' motion for summary judgment on Plaintiff's lawsuit alleging the use of excessive force in violation of the Eighth Amendment, holding that the district court failed to fulfill its obligation to follow the law as set forth in controlling precedent. The prison officials moved for summary judgment arguing that they were entitled to qualified immunity. The district court denied the motion. The record contained two versions of the relevant interaction between Plaintiff and prison officials. Under Scott v. Harris, 550 U.S. 372, 377 (2007), the district court's job was to decide whether the prison officials' evidence blatantly contradicted Plaintiff's version of events. The district court, however, rejected the teaching of Scott and denied the qualified immunity defense. The First Circuit held that the court's denial of qualified immunity was predicated on its error of law and remand to another district court judge for further proceedings consistent with the law was required. View "Underwood v. Barrett" on Justia Law