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Gidarisingh v. McCaughtry
Citation: 451 F. App'x 572Docket: Nos. 09-3646, 11-2361
Court: Court of Appeals for the Seventh Circuit; November 30, 2011; Federal Appellate Court
Sonniel Gidarisingh filed a lawsuit under 42 U.S.C. § 1983 against 18 employees of the Wisconsin prison system, alleging retaliation and excessive force during his incarceration. Following a bench trial, the district court ruled in favor of the defendants and subsequently denied Gidarisingh’s motion for relief from the judgment. Gidarisingh's claims arose after he testified in a separate case regarding the suicide of inmate Matthew Sanville, leading to alleged retaliatory actions against him by prison staff, which included deprivation of meals and misconduct reports, spanning five years across two facilities. He accused 15 employees of retaliatory behavior, ultimately dismissing his claim against one before trial. Additionally, Gidarisingh claimed that in 2003, three guards used excessive force against him during an incident where he was restrained. He recounted being violently handled and strip-searched after a verbal exchange with the guards, leading him to believe he had sustained severe injuries. The guards provided contrasting testimonies, asserting that Gidarisingh had defied instructions and posed a threat, justifying their actions. Notably, evidence was lacking regarding the involvement of two key defendants. Guards asserted that Gidarisingh, despite being restrained, remained a threat due to his potential to knee, elbow, kick, bite, or spit at them, and indicated that a strip search is standard for inmates involved in altercations. They denied any physical abuse after subduing him. A nurse examined Gidarisingh post-conflict and noted only superficial injuries. The district court ruled in favor of the defendants, finding their testimonies credible while rejecting Gidarisingh's claims of retaliation and excessive force. The court concluded that the guards did not retaliate, as they were unaware of Gidarisingh’s involvement in a related case. On the excessive force claim, the judge accepted the assertion by Guard Pitzen that he perceived a threat based on Gidarisingh's tense arm and found no evidence that Gidarisingh was beaten after being subdued. Gidarisingh, now representing himself, appealed, claiming the trial evidence did not support the judgment and alleging perjury by the defendants. The court clarified that Rule 50, regarding jury trials, was not applicable since the case was a bench trial governed by Rule 52, which allows for preservation of appeal issues without a specific motion. The appellate review found no clear error in the district court's credibility assessment or factual conclusions. Gidarisingh's argument that any use of force against restrained prisoners is excessive was dismissed, aligning with legal standards that measure force based on intent and context. The court also found no extraordinary circumstances justifying relief under Rule 60(b) from the judgment. Consequently, the district court's decisions were affirmed.