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Alfred Fraction v. Bishop L. Robinson Merry Copelin Robert Harleston Lewis Williams Ralph Logan Major Green Lenny Vann, Lieutenant R. Dennis, Lieutenant B. Brimer, Sergeant Darren Evans, Correctional Officer II H.T. Evans, Correctional Officer II E. Trader, Correctional Officer II T. Long, Correctional Officer II M. Czapkiewcz, Correctional Officer II M. Coulbourne, Correctional Officer II C. Laird, Correctional Officer II R. Moses, Correctional Officer II Captain Ritchey, and William Donald Schaefer, Governor Marvin N. Robbins Kenneth Taylor R. Austin, Correctional Officer II Harry Edwards, Trooper Carla Witcher H.J. Griffith, Correctional Officer III Sergeant Helman J.R. White M.J. Church Jane Doe, Nurse Floyd K. Warren Sean Jackson

Citations: 56 F.3d 61; 1995 U.S. App. LEXIS 19092; 1995 WL 318472Docket: 95-6050

Court: Court of Appeals for the Fourth Circuit; May 25, 1995; Federal Appellate Court

Narrative Opinion Summary

In this case, a Maryland prisoner challenged the magistrate judge's denial of relief on his 42 U.S.C. § 1983 complaint following an altercation with corrections officers. The incident arose when the prisoner, agitated over housing and disciplinary issues, left his cell against orders and resisted restraint, leading to a physical confrontation where he injured an officer. The magistrate judge found the officers' use of force justified, concluding that it was necessary and proportional. On appeal, the Fourth Circuit Court affirmed this finding, rejecting the prisoner's excessive force claim. The court also dismissed his allegations of due process violations during a disciplinary hearing and medical negligence as meritless. Furthermore, the appellate court denied the prisoner's motion for appointed counsel, noting the lack of complexity in the legal issues on appeal, and decided that oral argument was unnecessary. Consequently, the magistrate judge's summary judgment was upheld, affirming the decisions on all contested points.

Legal Issues Addressed

Appointment of Counsel in Civil Rights Appeals

Application: The court determined that the issues presented in the appeal were not complex, thus denying the motion for appointed counsel.

Reasoning: The court refused Fraction's motion for appointed counsel, stating the appeal did not present complex legal issues.

Due Process in Prison Disciplinary Hearings

Application: The court found no merit in the prisoner's claim of due process violations during the disciplinary hearing, affirming the procedural fairness of the process.

Reasoning: Fraction's allegations of report falsification, due process violations during a disciplinary hearing, and medical negligence by a nurse were deemed without merit.

Excessive Force under 42 U.S.C. § 1983

Application: The court evaluated the necessity and proportionality of the corrections officers' response to the prisoner's actions, ultimately finding it justified.

Reasoning: The Fourth Circuit Court upheld the magistrate judge's findings, rejecting Fraction's claim of excessive force, noting the necessity and proportionality of the officers' response.

Summary Judgment Affirmation

Application: The appellate court affirmed the magistrate judge's summary judgment, supporting the findings on all disputed issues.

Reasoning: The judgment of the magistrate judge was affirmed.