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Restraint Chair Use & Constitutional Rights

Handcuffs hang on the bars of a dimly lit prison cell, reflecting Restraint Chair Use & Constitutional Rights as the corridor stretches into the background with a sense of confinement and isolation.

When do officers violate an inmate’s constitutional rights by placing the inmate in a restraint chair? In the case of Plaintiff-Appellant v. Wood Cty. (In re Dustynolds), No. 22-40381, 2023 U.S. App. LEXIS 10593 (5th Cir. May 1, 2023), the courts explored the fine line between the legitimate use of restraint to ensure safety and potential violations of an inmate’s constitutional rights.

Constitutional Protections under the Fourteenth Amendment

The Fourteenth Amendment’s Due Process Clause serves as a safeguard for pretrial detainees. It protects them from excessive force and ensures their serious medical needs are addressed. When officers use restraint devices, such as restraint chairs, they must do so within the boundaries of constitutional protections. Moreover, officers must balance safety concerns with an inmate’s basic rights.

Proving Deliberate Indifference

To establish a violation of constitutional rights by use of a restraint chair, an inmate must demonstrate that officers acted with deliberate indifference. This requires proving that:

  1. Substantial Risk of Harm: The inmate must show that officers were aware of facts indicating a substantial risk of harm, such as potential physical and medical complications. Even so, officers still placed the inmate in the restraint chair.
  2. Disregard for Risk: It must be proven that the officers deliberately disregarded this risk by failing to act, such as by refusing to provide medical treatment. Alternatively, they may have ignored the inmate’s complaints of pain or distress.
  3. Obvious Risk: Courts may infer deliberate indifference if the risk to the inmate was obvious, such as visible medical distress. Nevertheless, officers must have still failed to intervene or provide proper medical care. This is true even though they should have known intervention was necessary.

In Plaintiff-Appellant v. Wood Cty, the court highlighted the need for officers to maintain vigilance and to respond appropriately to inmate complaints or visible signs of distress while in restraint. For example, the court emphasized that officers properly checked on the inmate every 15 minutes. Ignoring or delaying medical attention could constitute deliberate indifference and a constitutional violation.

Adherence to Police and Regular Monitoring

Correctional facilities generally have strict policies regarding the use of restraint chairs, with guidelines that specify time limits, medical evaluations, and regular monitoring of the inmate. Officers are expected to:

  • Follow Agency Policies: Proper adherence to policies regarding the restraint chair ensures that inmates are restrained only as long as necessary. This minimizes the risk of harm.
  • Regular Monitoring: Once an inmate is placed in a restraint chair, officers must frequently check on the inmate’s physical and medical condition. They must ensure there are no signs of distress or worsening conditions. Additionally, failing to monitor an inmate can expose officers and the facility to liability.

To stay informed about legal updates in corrections and ensure compliance with best practices, check out Jail Pro by Police Legal Sciences. Our corrections-specific caselaw training helps officers remain up to date with current legal standards and avoid costly legal issues.