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Mason v. Holiday

United States District Court, E.D. Arkansas, Western Division

October 4, 2017



         I. Background

         Timothy Scott Mason, an Arkansas Department of Correction inmate formerly detained at the Pulaski County Regional Detention Facility (“Detention Facility”), filed this civil lawsuit without the help of a lawyer under 42 U.S.C. § 1983. (Docket entry #2) Mr. Mason complains that Defendant Crockett used excessive force against him during his arrest and that Defendant Blocker failed to intervene to protect him. In addition, Mr. Mason alleges that Defendants Holladay and Morgan failed to adequately train Pulaski County (“County”) officials.[1]

         All Defendants have now moved for summary judgment on Mr. Mason's claims. (#161, #164) Mr. Mason has responded to the motions (#168), and Defendants have replied (#169).

         II. Discussion

         A. Standard

         In a summary judgment, the Court rules in favor of a party before trial. A party is entitled to summary judgment if the evidence, viewed in a light most favorable to the party on the other side of the lawsuit, shows that there is no genuine dispute about any fact important to the outcome of the case. Fed.R.Civ.P. 56; Celotex Corp. v. Catrett, 477 U.S. 317, 322-23, 106 S.Ct. 2548 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 246, 106 S.Ct. 2505 (1986).

         B. Factual Background

         On November 13, 2015, Defendant Blocker initiated a traffic stop of Mr. Mason's vehicle for fictitious plates. (#166-1 at p.1) After Defendant Blocker identified Mr. Mason, he ran an ACIC/NCIC check and determined that there were two outstanding warrants for Mr. Mason's arrest. (Id.) At that point, Defendant Blocker attempted to place Mr. Mason under arrest. (Id.) Mr. Mason, however, refused to comply and fled. Defendant Blocker chased Mr. Mason on foot for approximately one-hundred yards.[2](Id.; #166-2 at p.1) Defendant Blocker eventually employed the use of a taser and apprehended Mr. Mason without further incident. (#166-1 at p.1)

         Defendant Crockett, Sergeant Brewer (not a party to this lawsuit), and emergency personnel then arrived on the scene. (#166-2 at p.1) The emergency personnel removed the taser prongs from Mr. Mason, conducted a medical assessment, and released Mr. Mason to the deputies. (Id.) Defendant Crockett placed Mr. Mason into his patrol car and transported him to the location of the initial stop. (#163-5 at p.65; #166-4 at p.17) When they arrived at the place of the initial stop, Defendant Crockett walked Mr. Mason to Defendant Blocker's SUV. (#163-5 at p.66; #166-4 at p.17) Because Mr. Mason was unable to walk effectively after being tased, he was unable to step up into Defendant Blocker's SUV. Defendant Crockett, therefore, picked him up and placed him in the vehicle. (#166-4 at p.17) Defendant Blocker then transported Mr. Mason to the Detention Facility.

         Upon arrival at the Detention Facility, a medical history and screening form was completed for Mr. Mason, during which he complained of wrist pain. Mr. Mason consistently complained of wrist pain during his detention. According to his medical records, on December 23, 2015, an x-ray of Mr. Mason's hand revealed that his wrist was sprained, rather than broken. (#163-8 at p.2) Mr. Mason was prescribed ibuprofen for pain and scheduled for a follow-up appointment. (Id.) Although Detention Facility officials requested an orthopedics appointment through the Arkansas Department of Correction, ADC officials denied the request. (#163-9 at p.6) Mr. Mason was placed in a half-cast for six weeks. (Id.)

         C. Defendant Crockett

         For purposes of this motion, the Court will assume that Mr. Mason's allegations are true. According to Mr. Mason, he told Defendant Crockett that he could not get into Deputy Blocker's SUV because his legs were not functioning properly after being tased. Mr. Mason alleges that Defendant Crockett “grabbed me by the handcuffs, lifted me up, and threw me down like a sack of potatoes.” (#166-4 at p.18) Mr. Mason explains that when that occurred, “my handcuff twisted, and I landed on this hand.” (#163-5 at p.30; #166-4 at p.8)

         Mr. Mason's excessive force claim against Defendant Crockett is analyzed under the reasonableness standard of the Fourth Amendment. McKenney v. Harrison, 635 F.3d 354, 359 (8th Cir. 2011). Under the Fourth Amendment, the Court must determine “whether the amount of force used was objectively reasonable under the particular circumstances.” Brown v. City of Golden Valley, 574 F.3d 491, 496 (8th Cir. 2009). This requires the Court to determine “whether a use of force was reasonable by balancing the nature and quality of the intrusion on the individual's Fourth Amendment interests against the countervailing governmental interests at stake.” McKenney, 635 F.3d at 359 (internal quotation marks and citation omitted).

         The degree of injury suffered is also relevant to the excessive force inquiry. Chambers v. Pennycook, 641 F.3d 898, 906 (8th Cir. 2011). “Not every push or shove, even if it may later seem unnecessary in the peace of a judge's chambers, violates the Fourth Amendment.” Cook v. City of Bella Villa, 582 F.3d 840, 849 (8th Cir. 2009). The Court must be careful to analyze the facts without 20/20 hindsight, which ...

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