Inmate’s Excessive-Force Case Revived by 3rd Cir.

PHILADELPHIA (CN) - The Third Circuit revived claims from a prisoner who had to endure 14 hours in a four-point restraint chair after years of solitary confinement.

Leonard Young Jr., a prisoner with a history of mental illness, has spent the past six years in solitary confinement, let out of his cell for only one hour a day to recreate in a caged area, according to the ruling.

Pennsylvania prison records say the 29-year-old is an inmate at the State Correction Institute in Albion, but Young was at the Greene County facility in September 2009 when someone in the prison control room accidentally unlocked the door of his cell.

Young ascended to the tier of the prison's law library and began shouting for seven minutes about prisoner rights.

Surveillance cameras show that correctional officers in the floors below laughed and told Young to return from the balcony. Young complied and did not resist as the officers shackled his wrists and ankles. They then took the inmate to a medical room where they cut off his clothes and searched him in a prone position.

Officers then hauled in a restraint chair and strapped Young into it at 8:46 p.m. Though Young complained that the smock placed on his lap failed to cover his genitals, the officers refused to reposition it.

When he was released at approximately 10:30 a.m., Young was shaking uncontrollably. The man said that he was "cold down to his bones" because the air conditioner had been blowing at his naked body for so long.

With Young's legs too numb for him to walk, he had to be wheeled back to his cell in solitary.

The chair's manufacturer advises against restraint for longer than two hours. Prison regulations bar restraint for longer than eight hours absent special authorization, which the officers did not seek from administrators before shackling Young.

Though Young claimed in a lawsuit that the punitive action taken against him violated his Eighth Amendment rights, a federal judge in Pittsburgh ruled for the defendants at summary judgment, finding that they had "acted professionally and within constitutional parameters."

A three-judge panel with the Third Circuit reversed Tuesday, saying the lower court failed to fully consider the lack of threat Young posed during the incident prior to his restraint.

"Young only left his cell because a CO inadvertently opened his cell door - far from a prison break; the incident lasted a mere seven minutes, during which two COs chatted and laughed while they watched the scene unfold; and Young voluntarily complied with the COs' instructions within that short time frame," Judge Cheryl Krause wrote for the court.

A "reasonable jury" could determine that there were no safety concerns by the time Young reached the chair, according to the ruling.

Young's symptoms of mental illness, variously diagnosed as bipolar and schizoaffective disorder, have intensified since his time in solitary confinement, the court found.

He now suffers from "visual and auditory hallucinations, paranoid thoughts, throwing and smearing his own feces, episodes of self-harm, and suicidal impulses," according to the ruling.

"Indeed, since living in these conditions of prolonged isolation, his numerous suicide attempts have included efforts to hang himself and to break his own neck by banging his head against the wall," the ruling continues.

In a footnote, the panel noted that the claims at issue here concern whether the use of mechanical restraints amounted to excessive force, nit that the record on Young's detention in solitary confinement "raise serious concerns under the Eighth Amendment's conditions of confinement test."

"As Justice Kennedy recently observed, 'years on end of near-total isolation exact a terrible price,'" Krause wrote, citing an investigative report from the Justice Department regarding prolonged solitary confinement at SCI-Greene and five other Pennsylvania prisons.

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