Welters v. Minn. Dep't of Corr.

• Decision Date: 14 December 2022
• Docket Number: A20-1481
• Citation: 982 N.W.2d 457
• Parties: Christopher WELTERS, Respondent, v. MINNESOTA DEPARTMENT OF CORRECTIONS, et al., Appellants.
• Court: Minnesota Supreme Court

982 N.W.2d 457

Christopher WELTERS, Respondent,

v.MINNESOTA DEPARTMENT OF CORRECTIONS, et al., Appellants.

A20-1481

Supreme Court of Minnesota.

Filed: December 14, 2022

Zorislav R. Leyderman, The Law Office of Zorislav R. Leyderman, Minneapolis, Minnesota, for respondent.

Keith Ellison, Attorney General, Michael Goodwin, Assistant Attorney General, Saint Paul, Minnesota, for appellants.

Vicki A. Hruby, Jardine, Logan & O'Brien, P.L.L.P., Lake Elmo, Minnesota, for amicus curiae Association of Minnesota Counties.

John J. Choi, Ramsey County Attorney, Rebecca Krystosek, Assistant County Attorney, Saint Paul, Minnesota, for amicus curiae Minnesota County Attorneys Association.

Richard D. Hodsdon, Minnesota Sheriffs’ Association, Saint Paul, Minnesota, for amicus curiae Minnesota Sheriffs’ Association.

OPINION

THISSEN, Justice.

The Eighth Amendment to the United States Constitution prohibits inflicting "cruel and unusual punishments." U.S. Const. amend. VIII ; see also Wilson v. Seiter , 501 U.S. 294, 296–97, 111 S.Ct. 2321, 115 L.Ed.2d 271 (1991). Respondent Christopher Welters is incarcerated in the Stillwater correctional facility. On July 31, 2017, he was transported from the Stillwater correctional facility to the Oak Park Heights correctional facility for an endoscopy

. Welters alleges that Appellants Cornelius Emily and Ernest Rhoney, Minnesota Department of Corrections officers, subjected him to cruel and unusual punishment when they improperly applied handcuffs in a manner that caused him injury and refused to loosen the handcuffs when he complained that the handcuffs were too tight and causing numbness. Welters remained in the overtightened handcuffs for 3½ hours, including while under general anesthesia for the endoscopy. Welters suffered serious injury in both wrists that required surgery and left him with permanent nerve damage that continues to cause pain and decreased function. He sued Officers Rhoney and Emily under 42 U.S.C. § 1983, seeking damages to compensate him for his injuries.

We are asked to answer two questions in this case. First, we must determine whether Welters's Eighth Amendment claim should be assessed under the deliberate indifference standard (applicable to conditions of confinement and medical care) or under the malicious and sadistic standard (applicable in Eighth Amendment excessive use of force cases). Eighth Amendment claims arising from conditions of confinement and medical care are subject to the deliberate indifference standard, which asks whether officers knowingly disregarded an objective risk of serious harm. Wilson , 501 U.S. at 303, 111 S.Ct. 2321. In contrast, when officers take security measures to "resolve a disturbance" that "indisputably poses significant risks to the safety of inmates and prison staff," the applicable Eighth Amendment standard is "whether force was applied in a good faith effort to maintain or restore discipline or maliciously and sadistically for the very purpose of causing harm." Whitley v. Albers , 475 U.S. 312, 320–21, 106 S.Ct. 1078, 89 L.Ed.2d 251 (1986) (citation omitted) (internal quotation marks omitted). We conclude that the deliberate indifference standard applies in this case.

Second, we must determine whether qualified immunity bars Welters's deliberate indifference claim. This analysis has two parts. As an initial matter, because this case comes to us from a district court decision granting summary judgment in favor of Officers Rhoney and Emily, we must assess whether a jury, viewing the facts and inferences drawn from those facts in the light most favorable to Welters, reasonably could find that the corrections officers acted with deliberate indifference. We conclude that a jury could do so.

Next, we must decide whether, on July 31, 2017, a reasonable corrections officer would have known that improperly applying handcuffs for routine medical transportation in a manner that caused serious injury and refusing to loosen the overtightened handcuffs when Welters complained that they were too tight and causing him numbness, violated Welters's Eighth Amendment rights. We conclude that a reasonable corrections officer would have understood that such conduct violated the Eighth Amendment's prohibition on cruel and unusual punishment. Accordingly, the right was clearly established such that Officers Rhoney and Emily are not entitled to qualified immunity.

Accordingly, we hold that Welters's section 1983 claim survives summary judgment. We affirm the decision of the court of appeals, which reversed the district court's decision to grant summary judgment in favor of Officers Rhoney and Emily, and we remand for further proceedings in accordance with this opinion.

FACTS

We are reviewing the district court's decision to grant summary judgment in favor of Officers Rhoney and Emily. Accordingly, we recite the facts in the light most favorable to Welters as the nonmoving party. Mumm v. Mornson , 708 N.W.2d 475, 481 (Minn. 2006). These facts are, of course, subject to proof at trial.

On July 31, 2017, Officers Rhoney and Emily were tasked with transporting inmates from the Minnesota Correctional Facility–Stillwater to their appointments scheduled at the outpatient medical clinic housed at the Minnesota Correctional Facility–Oak Park Heights. Welters was an inmate at Stillwater and was scheduled for a routine endoscopy

under general anesthesia that day at Oak Park Heights. He had been incarcerated for nearly 30 years and testified that, during that time, he had no altercations with officers, no assaults on other inmates, and no escape attempts. Officers Rhoney and Emily both testified that they did not have any specific safety or security concerns about Welters, and Officer Rhoney testified that this was just a "routine" transportation for medical treatment.

Minnesota Department of Corrections (DOC) policy requires that all offenders be transported in full restraints, regardless of the individual offender's security classification. Minn. Dep't of Corr., Policy Manual 301.096(C)(1) (Nov. 5, 2019).¹ Full restraints include handcuffs, a waist chain, a black box (applied over the chain and lock area of handcuffs to form a rigid link between the two wristlets), and leg irons

. Id. at 301, 111 S.Ct. 2321.096. DOC Policy also requires handcuffs and leg irons to be "double locked"—a safety measure that prevents the cuffs from continuing to tighten. Id.

When Officer Rhoney applied Welters's restraints in preparation for transport, Welters testified that he noticed right away that the handcuffs were "tighter than usual," but he did not mention it to Officer Rhoney at that time because he "didn't think it was important." About 15 to 20 minutes later, however, Welters began feeling symptoms. He testified that prior to getting into the transport vehicle, he told Officer Rhoney that the cuffs were "pretty tight." Welters testified that Officer Rhoney responded, "Oh, it's only a 15-minute drive, it'll be all right."

When they were getting into the van, Welters felt his handcuffs click tighten, indicating that they were not double locked in violation of DOC policy. When Welters mentioned this to Officer Rhoney and asked him to "fix this before we leave," Officer Rhoney pushed on the cuff, clicked it even tighter, told Welters he "was right," but then did nothing to correct the situation, repeating that they would be there in only 15 minutes.

During the drive to Oak Park Heights, Officer Rhoney sat in the back of the vehicle with Welters and one other inmate, and Officer Emily rode in the front with a third officer. Upon arrival at Oak Park Heights, neither Officer Rhoney nor Officer Emily did anything to tend to Welters's overtightened handcuffs. Rather, Welters and the other Stillwater inmate were placed in medical holding cells and left alone, still in full restraints. Welters noticed that none of the other eight inmates in the other medical holding cells had any restraints on. The third officer and Officer Rhoney then left to go back to Stillwater, leaving Officer Emily at Oak Park Heights. Welters estimates that he and the other Stillwater inmate were left alone for at least half an hour, during which time his hands were becoming increasingly cold and numb. Welters testified that, in his decades of incarceration, he had been transported "many, many, many times" and that this was the first time handcuffs had been put on too tight. Welters asked an Oak Park Heights officer about getting his restraints removed and that officer responded that a Stillwater officer would need to attend to that.

Welters testified that when Officer Emily came back about 45 minutes later and opened the door to the cell, Welters told him that his hands were numb and asked Officer Emily to "loosen them, please loosen them." Officer Emily did nothing to fix Welters's handcuffs. Stating that he needed to go find the other Stillwater officers, Officer Emily closed the door of the holding cell and left. According to Welters, that was the last time he saw Officer Emily until after he was recovering from anesthesia and the procedure.

When an Oak Park Heights officer came to take him back for his procedure, Welters asked that officer to loosen his restraints and the officer responded that he would have to get a Stillwater officer to do that. Welters testified that the nurse then asked that officer "Why is he still in his restraints?" and the Oak Park Heights officer replied that he was looking for Stillwater officers. According to Welters, the nurse then asked Welters why he was still in restraints, expressed that it was not normal for inmates to remain in restraints during the procedure, and stated to another officer, "Why are these offender's restraints still on? I said I wanted them removed." Welters testified that he could "barely sign" the pre-procedure paperwork because his hands were "so numb," although they were not yet blue. When he told the nurse how numb his hands were, she reportedly stated that "the...