ANNAPOLIS – A federal appeals court has overturned a lower court’s award of damages to a Maryland prison inmate who claimed guards used excessive force to subdue him during a Jan. 6, 1994, riot.
A three-judge panel of the 4th U.S. Circuit Court of Appeals ruled that corrections officers at the Maryland House of Correction in Jessup did not violate Steven C. Stanley’s Eighth Amendment protection from cruel and unusual punishment.
Stanley, who has been in prison since 1979 on a 20-year sentence for armed robbery, has been a discipline problem, according to court records. He was being held in a section of the prison reserved for inmates who have committed disciplinary violations when the violence erupted.
The uprising began after an inmate request for recreation was denied. According to court documents, inmates plugged up their toilets and dropped burning paper out of their cells to set off the sprinklers, in an attempt to flood the area.
Stanley was identified as a “primary trouble maker” during the incident and ordered into isolation by the shift commander.
As he was being removed from his cell, court records say, Stanley said he would stab the officers. Cursing, he also threatened further trouble, which he later testified meant he wanted to set more fires.
Officers involved in the struggle testified that Stanley was resisting and kicking, which is evident in a tape of the incident taken from prison video cameras. The tape also shows Stanley on the ground at one point with officers leaning on him while they try to put him in leg irons and stronger handcuffs.
But in Stanley’s version of the incident, officers leading him to isolation “took and mashed my head on the side of the door” while they were momentarily out of sight of video cameras.
The officers took Stanley for medical treatment, which he refused before being taken back to an isolation cell.
Magistrate Judge James E. Kenkel of the U.S. District Court in Baltimore awarded Stanley $2,000 in punitive damages and $1,000 in compensatory damages for injuries he received while being cuffed.
But the appellate court, in a Jan. 21 decision, said the magistrate judge failed to take into account the tension of the prison riot.
The appeals court said that, in order to make his case, Stanley would have had to show that the officers inflicted unnecessary and wanton pain and suffering on him and acted excessively in the context of quelling a rebellion.
Assistant Attorney General Glenn William Bell, who defended the 12 corrections officers, said he thinks the reversal “corrected a wrong made in the lower court.” Stanley’s attorney could not be reached for comment Tuesday.