Corrections officers frequently encounter combative inmates. In these situations, it’s important to recognize The Line Between Firm and Abusive in Corrections. When an inmate refuses to comply with an officer’s orders, it can sometimes be difficult in the moment to determine the best method of bringing the inmate under control. There are many competing considerations in these scenarios, such as the threat the inmate may pose to themselves and other inmates, the possibility that one inmate’s disruptive behavior will encourage other inmates to refuse orders, and officer safety. Also, discussions about The Line Between Firm and Abusive in Corrections are crucial in such challenging environments.
Because these situations can develop rapidly, officers must be able to rely on their training to guide them to the appropriate response. Officers should be familiar with agency policy about when to employ force in response to combative inmates and ensure that any use of force is only applied in a good-faith effort to maintain or restore discipline while staying within The Line Between Firm and Abusive in Corrections.
But what about other scenarios where an immediate use of force is not necessary against an inmate, but a passive restraint must still be employed to maintain discipline? For example, passive restraints like handcuffs or leg restraints can still be considered excessive when the use of the restraints is disproportionate to their need. Therefore, it is essential for officers to understand when an action crosses The Line Between Firm and Abusive in Corrections.
One such case was considered by the United States Court of Appeals for the Eighth Circuit in Evans v. Smith, 153 F.4th 613 (8th Cir. 2025). In that case, officers followed agency policy and placed an inmate in leg restraints while escorting the inmate to an educational program. However, when the officers brought the inmate back to his cell, they left the inmate in the leg restraints for about 15 hours, causing the inmate pain.
Based on the facts as alleged in the case, because the inmate was alone in his cell and was not actively resisting the officers, the court of appeals determined there was no legitimate reason for the officers to keep the inmate in leg restraints. As a result, a reasonable jury could find the officers used excessive force against the inmate, even though the only force used was the passive restraint. The court of appeals permitted the case to proceed to trial.
The Evans case highlights the reality that “excessive force” can mean more than force directly applied to an inmate to gain compliance. Officers must be mindful any time they place an inmate in restraints that the use of the restraints is considered a use of force.
Interested in learning more?
PLS offers correctional officers online legal training link: https://www.policelegalsciences.com/ on a wide variety of practical issues to help them make good decisions in challenging situations.