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Ramsey v. St. Charles County

United States District Court, E.D. Missouri, Eastern Division

June 30, 2017

ST. CHARLES COUNTY, et al., Defendants.



         Plaintiff Patsha Ramsey brings this action under 42 U.S.C. § 1983 and state law against St. Charles County (“the County”) and Larry Crawford (“Crawford”), Director of the St. Charles County Jail (“the Jail”), in his individual and official capacities, arising from her treatment while a pretrial detainee in the custody of the St. Charles County Jail.[1] Plaintiff alleges Defendants subjected her to excessive force amounting to cruel and unusual punishment, and deprived her of necessary medical care. Plaintiff further alleges Defendants were negligent under Missouri state law in their failure to keep her safe and free from harm during her detention. This matter is before the Court on Defendants' Motion for Summary Judgment on Plaintiff's First Amended Complaint (Doc. No. 39). The motion is fully briefed and ready for disposition. For the following reasons, Defendants' motion will be granted in part and denied in part.

         I. Background[2]

         Plaintiff was a pretrial detainee confined at the Jail between December 2012 and September 2013. In December 2012, while a patient at CenterPointe Psychiatric Hospital in St. Charles, Missouri, Plaintiff was involved in an altercation with a nurse. She was arrested at the hospital, transferred to the Jail, and charged with felony assault. Soon thereafter, Plaintiff attempted suicide and was transferred to a suicide prevention housing unit at the Jail, where she remained for the duration of her detention.

         Plaintiff contends correctional officers at the Jail labeled her a “problem inmate, ” and used this as a pretext to inflict abusive and cruel punishment on her, which included taking her clothing without cause and forcing her to be in her cell naked; denying her food as a punishment for bad behavior; and physically assaulting her, including the unnecessary use of pepper spray. She claims she was handcuffed to a table for extended periods of time wearing nothing but a “suicide smock, ” and that on several occasions she was tied to a “restraint chair” while naked. During these periods, Plaintiff alleges she was subjected to humiliation, degradation and physical assaults from correctional officers and other inmates. In addition, Plaintiff claims she received no medical treatment for her known mental health condition during her detention.

         Defendant Crawford is the highest ranking official at the Jail and the person ultimately responsible for setting and overseeing Jail policies, procedures and daily operations. The St. Charles County Department of Corrections (“SCCDOC”) has Department-wide policies concerning the use of force, restraints, and pepper spray. In instances requiring the use of force, it is SCCDOC's policy to ensure that Department personnel “use only that force necessary to effect lawful objectives, ” i.e., “lawful restraint, apprehension, detention or in defense of the Officer or of another human being” (Doc. No. 39-2). SCCDOC prohibits the use of restraining devices or methods as a form of punishment or “for more time that is absolutely necessary” (Doc. No. 39-3). It is also SCCDOC policy that oleoresin capsicum spray (more commonly referred to as OC spray or pepper spray) is to be deployed exclusively as a control agent for inmates who pose a serious physical threat to staff or other inmates, inmates who pose a serious threat to the safe, secure and orderly operation of the facility, or as a tactical agent in quelling a fight, disturbance or riot situation. Training is required before any SCCDOC staff may carry and use OC spray. (Doc. No. 39-4).

         II. Legal standard

         Summary judgment is appropriate when no genuine issue of material fact exists in the case and the movant is entitled to judgment as a matter of law. See Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986). The initial burden is placed on the moving party. City of Mt. Pleasant, Iowa v. Associated Elec. Co-op., Inc., 838 F.2d 268, 273 (8th Cir. 1988). If the record demonstrates that no genuine issue of fact is in dispute, the burden then shifts to the non-moving party, who must set forth affirmative evidence and specific facts showing a genuine dispute on that issue. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). In determining whether summary judgment is appropriate in a particular case, the court must review the facts in a light most favorable to the party opposing the motion and give that party the benefit of any inferences that logically can be drawn from those facts. Buller v. Buechler, 706 F.2d 844, 846 (8th Cir. 1983). The court is required to resolve all conflicts of evidence in favor of the nonmoving party. Robert Johnson Grain Co. v. Chem. Interchange Co., 541 F.2d 207, 210 (8th Cir. 1976).

         III. Discussion

         A. § 1983 Claims

         1. Excessive force-cruel and unusual punishment

         Plaintiff alleges Defendants subjected her to unreasonable and excessive force and cruel and unusual punishment, including the use of unnecessary and unlawful restraints and the unnecessary use of pepper spray. (First Amended Complaint (“FAC”), Doc. No. 6 at ¶¶ 34, 35). The Due Process Clause of the Fourteenth Amendment protects pretrial detainees from “the use of excessive force that amounts to punishment.” Graham v. Connor, 490 U.S. 386, 395 n. 10 (1989) (citing Bell v. Wolfish, 441 U.S. 520, 535-39 (1979)); see also Edwards v. Byrd, 750 F.3d 728, 732 n. 2 (8th Cir. 2014) (pretrial detainee's right to be free from excessive force is founded on the Due Process Clause and, unlike the Eighth Amendment, the Clause prohibits any punishment of a pretrial detainee, whether cruel-and-unusual or not). Thus, a court must decide whether force was applied in a good-faith effort to maintain or restore discipline, or “to injure, punish or discipline” the detainee. Id. at 732 (quoting Putman v. Gerloff, 639 F.2d 415, 421 (8th Cir. 1981)). An official's use of force does not amount to punishment in the constitutional sense if it is “but an incident of some other legitimate governmental purpose.” Bell, 441 U.S. at 535, 538 (providing an analogous rule in the context of a conditions-of-confinement challenge brought by pretrial detainees). Moreover, conduct that is merely negligent or grossly negligent does not implicate the protections of the Due Process Clause. See, e.g., Daniels v. Williams, 474 U.S. 327, 328 (1986); Clemmons v. Armontrout, 477 F.3d 962, 966 (8th Cir. 2007); Wilson v. Lawrence Cnty., 260 F.3d 946, 955 (8th Cir. 2001).

         In deciding whether the force used against a pretrial detainee is “excessive, ” “a pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable.” Kingsley v. Hendrickson, 135 S.Ct. 2466, 2472-73 (2015). “[O]bjective reasonableness turns on the ‘facts and circumstances of each particular case.'” Id. Factors relevant to assessing the objective reasonableness of force used include: “the relationship between the need for the use of force and the amount of force used; the extent of the plaintiff's injury; any effort made by the officer to temper or to limit the amount of force; the severity of the security problem at issue; the threat reasonably perceived by the officer; and whether the plaintiff was actively resisting.” Id. (citing Graham, 490 U.S. at 396). In accordance with Kingsley, the Court makes the reasonableness determination from the perspective of a reasonable officer on the scene; accounts for the legitimate interests that stem from the need to manage the facility; and gives deference to SCCDOC policy[3] which allows the use of restraints “to prevent self-injury or injury to others.” Id. at 2473.

         a. County and Crawford in his official capacity

         In a § 1983 action, a local government may be held liable only if the plaintiff identifies a particular policy, custom, or practice that resulted in the alleged constitutional violations.[4]Monell v. Dep't of Soc. Serv., 436 U.S. 658, 690-91 (1978); City of Canton, Ohio v. Harris, 489 U.S. 378, 388-89 (1989); Ware v. Jackson Cnty., Mo., 150 F.3d 873, 880 (8th Cir. 1998). Defendants argue that summary judgment is appropriate because there is no evidence of a facially unconstitutional policy, or a causal connection between a policy and Plaintiff's alleged constitutional violations, citing Monell. According to Plaintiff's own expert, the SCCDOC policies regarding use of force, restraints, and pepper spray appear to be constitutional, as they comply with correctional industry standards. (Deposition of Dr. Thomas Shull (“Shull Depo.”), Doc. No. 39-5 at 18:8-13; 19:12-25; Doc. No. 44-13 at 33:18-34:2; 46:24-47:13). Plaintiff responds that the existence of written policies does not relieve a defendant of liability when it has a custom of ignoring those policies, citing Ware, 150 F.3d at 882, and that in this case, Defendants had a custom of depriving her of her constitutional rights through excessive force and cruel and unusual punishment (Doc. No. 45 at 10-11).

         Restraint to table

         On two separate occasions during her detention, Plaintiff was restrained to a dayroom table in her housing unit by a chain approximately three feet in length, secured either to her wrist or ankle. Crawford testified that because Plaintiff was frequently confined to her cell for disciplinary reasons, he consulted with medical staff and the Assistant Director about restraining her to the dayroom table to get her out of her cell (Deposition of Larry Crawford (“Crawford Depo.”), Doc. No. 39-6 at 92:18-93:11; 96:3-10; 98:7-17). Crawford acknowledged the practice was “unusual” and not “within [their] normal procedures” (Crawford Depo., Doc. No. 44-3 at 104:1-8; 105:12-13), but considered it acceptable because they routinely restrain inmates to a bench or chair while awaiting booking or to see medical (id. at 95:21 to 98:4; 100:24-101:11).

         The April 19, 2013 directive to Jail staff, issued by Assistant Director Vaughn, states:

Because of Inmate Patsy [sic] Ramsey's continuous self-harm and until further notice, she (Ramsey) is to be out of her cell on the first and second shifts and restrained to the table in the dayroom. Staff with back up is expected to allow her (Ramsey) to utilize the restroom on an hourly basis or as needed.
Because Inmate Ramsey is still classified as “constant”[5], during the night shift, she (Inmate Ramsey) will remain in the dayroom secured to the table but will be allowed to sleep on a portable bunk. Her use of ...

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