Gaddis v. Johnson

On June 2, 2023, the U.S. Court of Appeals for the Eleventh Circuit issued its decision in Gaddis v. Johnson. The case stemmed from a 2017 incident at St. Clair Correctional Facility in Alabama, where inmate Marcus Gaddis, who was handcuffed and compliant, was allegedly struck in the face and head by Officer Johnson's knee. The district court had granted summary judgment in favor of Officer Johnson on the basis of qualified immunity. The appellate court reversed that decision, finding that the law was clearly established at the time of the incident that delivering a knee strike to a non-resisting, restrained prisoner constitutes excessive force in violation of the Eighth Amendment. The case was remanded for further proceedings.

The Eleventh Circuit Court of Appeals reversed the district court’s grant of summary judgment, denied qualified immunity to Officer Johnson, and remanded the case for trial.

Whether Officer Johnson was entitled to qualified immunity for using a knee strike on a handcuffed and compliant inmate, and whether such force constituted cruel and unusual punishment under the Eighth Amendment.

The ruling clarified that using significant force against restrained, non-resistant prisoners violates clearly established law, limiting the use of qualified immunity defenses for correctional officers and reinforcing Eighth Amendment safeguards against excessive force.