Davis v. Wessel

In plaintiff-civil detainee’s section 1983 action alleging that defendants-security guards violated his right to be free from unreasonable restraints when defendants refused to take off his handcuffs in order to allow him to successfully use courthouse restroom, Dist. Ct. erred in giving jury instruction that did not require jury to find that defendants possessed purposeful, knowing or possibly reckless state of mind when taking actions against plaintiff. Moreover, said instruction improperly allowed jury to award plaintiff $1,000 in compensatory damages for defendants being merely negligent in keeping handcuffs on plaintiff’s hands while he used restroom. As such, defendants were entitled to new trial in which jury would still be free to find that defendants violated plaintiff’s constitutional rights by refusing to remove plaintiff’s handcuffs for purpose of humiliating and causing plaintiff psychological pain.