Long v. Waters et al

Inmate Anthony Long alleged that while handcuffed and compliant at Northwest Correctional Complex in Tennessee, Correctional Officer Tony Waters and other officers repeatedly punched and kneed him, causing facial fractures and other injuries. Long filed a civil rights suit under 42 U.S.C. § 1983, claiming excessive force in violation of the Eighth Amendment. The district court granted summary judgment to the defendants, ruling that Long failed to show the force was applied maliciously and that the officers were entitled to qualified immunity. On April 3, 2023, the U.S. Court of Appeals for the Sixth Circuit reversed in part, finding genuine disputes of material fact regarding whether Long posed a threat and whether the officers’ actions were a good-faith effort to restore discipline. The appellate court concluded a reasonable jury could find the force excessive, partially denied qualified immunity, and remanded for further proceedings.

The Sixth Circuit reversed the district court’s summary judgment in part, holding that genuine factual disputes precluded qualified immunity and required a jury determination on the excessive force claim; the case was remanded for trial.

Whether the correctional officers’ use of force against a handcuffed inmate constituted cruel and unusual punishment under the Eighth Amendment, and whether the officers were entitled to qualified immunity.

The ruling reinforced judicial scrutiny of prison abuse and limited the ability of correctional officers to obtain pre-trial dismissal based on qualified immunity when video or testimonial evidence conflicts. It was cited by advocates as a precedent for holding guards accountable for violence against restrained inmates.