Defoe v. Wise et al

Inmate Michael Defoe filed a 42 U.S.C. § 1983 lawsuit against Corrections Officer Jason Wise and others, alleging excessive force in violation of the Eighth Amendment at Crossroads Correctional Center in Montana. Defoe claimed that while he was restrained in a chair, Wise punched him multiple times and used pepper spray without justification. The U.S. District Court granted summary judgment in favor of the defendants. On March 8, 2023, the U.S. Court of Appeals for the Ninth Circuit issued a memorandum disposition that affirmed in part, reversed in part, and remanded, finding that a genuine dispute of material fact existed regarding whether the force was applied in a good-faith effort to restore discipline or maliciously and sadistically to cause harm.

The Ninth Circuit partly reversed the district court's grant of summary judgment, holding that a reasonable jury could find an Eighth Amendment violation, and remanded the excessive force claim against Officer Wise for further proceedings.

Whether the corrections officer's use of force against a fully restrained prisoner constituted excessive force under the Eighth Amendment, and whether the officer was entitled to qualified immunity given the disputed facts regarding the necessity and proportionality of the force.

The ruling reinforced constitutional limitations on the use of force against restrained inmates and clarified that factual disputes about an officer's motives can defeat qualified immunity at the summary judgment stage, providing important precedent for prisoner rights litigation in the Ninth Circuit.