Qualified Immunity

Federal Court Confirms That Shackling an Inmate During Exercise Is Cruel and Unusual Punishment

The warden at the center of the case was originally given qualified immunity.


A federal court has ruled yet again that shackling an inmate in full restraints while exercising qualifies as cruel and unusual punishment, and that a warden who allegedly flouted that rule is not protected by qualified immunity.

The U.S. Court of Appeals for the Second Circuit confirmed last week that Angel Quiros, formerly the warden at the Northern Correctional Institute in Somers, Connecticut, violated M.A. Edwards's Eighth Amendment rights when prison officials placed Edwards in restraints during his exercise time over a six-month period. Specifically, Edwards had his "hands cuffed," with "leg irons on [his] ankles" and "a chain tether securing those two sets of restraints to one another."

In 2014, a lower court gave Quiros qualified immunity, the legal doctrine that protects government officials from certain sorts of lawsuits if the alleged misbehavior was not "clearly established" in prior case law. In practical terms, that means courts often acknowledge that a civil servant infringed on a defendant's rights but—without a court precedent—still award that civil servant protection from accountability. (See also: the time the U.S. Court of Appeals for the Ninth Circuit gave qualified immunity to two police officers who stole $225,000 during a search warrant, because no court precedent said that stealing under those specific circumstances was definitively wrong.)

This case initially followed that pattern. The United States District Court for the District of Connecticut ruled that, while every inmate has the right "to recreate free from restraints," this was not a clearly established right. 

The Second Circuit countermanded that on appeal, allowing the case to go to a jury, which sided with Edwards in 2018. The district court then turned around and vacated that decision—a fairly uncommon move—maintaining that Quiros only had enough information to know of the violation for a short period of time, as opposed to the entire six months.

On appeal, Quiros raised that same concern, which the court rejected—citing Quiros's own testimony. The warden also challenged the idea that an Eighth Amendment violation occurred at all, arguing that "the plaintiff was not deprived of the ability to attend outdoor recreation and to get fresh air and walk." The Second Circuit wouldn't have it.

"We have described the right at issue as that to 'some opportunity to exercise,'" wrote Judge John M Walker, Jr., "and we cannot determine as a matter of law that the jury erred in finding that Edwards's limited ability to shuffle around in full restraints while breathing fresh air constituted meaningful exercise."

Quiros also argued that safety justified the restraints, thus undermining any constitutional claims. Again, no luck: "The jury was entitled to disagree," wrote Walker. "The safety justification was undermined by testimony from Edwards, credited by the jury, that corrections officers would not always employ the most restrictive shackling method of full restraints when they were moving him out of his cell and around the facility."

Bringing things full circle, Quiros again claimed qualified immunity—the same defense the Second Circuit rejected in 2015, which they again rejected in 2021. 

The denial of qualified immunity does not mean a defendant has been found guilty; it merely gives the plaintiff the right to sue. In other words, an official awarded the legal protection is thus spared from facing the possibility of accountability, not accountability itself. The latter comes in the form of a jury's decision—something that, in this case, already came down three years prior. 

"The jury reasonably determined, upon sufficient evidence, that Quiros knowingly violated Edwards's clearly established right to meaningful exercise under the circumstances and lacked a sufficient justification for doing so," notes Walker. "We will not disturb the jury's finding that Quiros was not entitled to qualified immunity."

NEXT: Thanks to Colorado's Reforms, Cops Who Forced Children To Lie on the Pavement at Gunpoint Might Be Held Accountable

Qualified Immunity Eighth Amendment Prisons Criminal Justice Courts Federal Courts Connecticut

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31 responses to “Federal Court Confirms That Shackling an Inmate During Exercise Is Cruel and Unusual Punishment

  1. Cruel certainly, but not that unusual.
    Prisoners used to be shackled and forced to work.

    1. Shackled – yes.
      Forced to work – yes.
      Forced to work while shackled – no, that would be stupid. You can’t do useful work while shackled in the way described in the article.

      Likewise, you can’t meaningfully exercise while shackled in that manner. The prison’s policy deprived the inmate of the opportunity to exercise. Reasonable people could disagree about whether prisons should be compelled to allow the opportunity for inmates to exercise but until that standard is changed, it is the rule and the warden had no legitimate basis for violating it.

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  2. Does he have to wear two masks also?

    1. If only the warden had argued that they shackled his hands behind his back to stop him from touching his face ….

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  4. “These inmates spent their recreation time with their hands cuffed behind their backs, leg irons on their ankles, and a chain tether securing those two sets of restraints to one another, which severely restricted the inmates’ freedom of movement.”

    Freedom of movement? Wait until they figure out what the cells are intended to do ….

    1. Spoken like a true authoritarian.

      1. Weren’t you celebrating the death of Ashli Babbitt at the hands of police just a couple of weeks ago?

        1. Nope. I merely pointed out that when a cop is pointing a gun at you and telling you not to do something, and you do it anyway, that what happens afterwards is your own damn fault. That isn’t celebrating anything. It’s just how life works.

          1. Spoken like a complete fucking retard.

            1. If you think what you’re doing is sarcasm, you should look up smarmy.

              1. After you look up butthurt.

          2. “Spoken like a true authoritarian.” -sarcasmic, 22 minutes prior to her next dumbass post.

      2. Rarely does one encounter people incapable of being sarcastic and incapable of understanding sarcasm.

    2. Christ, what a pain in the ass. Edwards kicked the living shit out of a guard at his prior institution, gets placed in segregation at a higher security one. But overcrowding is bad enough they can’t place him in the special exercise area where they can safely remove his shackles without him potentially beating the shit out of some more guards. Leaving him to rot in his cell is evidently not an option. And neither is shooting him in the fucking head the next time he tries to maim a guard, unfortunately.

      Naturally, he sues, and naturally, the 2nd decides to hear him out.

      What a complete waste of time.

      1. If you or someone you know has ever been to prison,

        The guard deserved it

        1. Maybe so. But you shouldn’t be surprised when you end up shackled everywhere afterwards.

      2. If restricting an inmate’s “freedom of movement” is cruel and unusual, how long until prisons are deemed to be unconstitutional?

        1. That can’t be a serious question. I mean, shackles vs fences and national borders… That has to be a joke of some kind. By someone who throws poop at me like a monkey.

          1. Drinking cologne again, I see.

  5. This is completely fake news and made up. The prison is a government run facility and not an icky for profit institute, nothing bad can happen there. We all know that bad things happen because of for profit companies

  6. This is clearly a large problem, and I’m glad reason is on the case because nothing else bad or problematic is going on.

  7. CT’s Gov announced that the Somers prison will be closed in July.

    Link is to the Hartford Courant.

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