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Jacobs v. Cumberland Co.

3rd Circuit

August 10, 2021

The Third Circuit affirmed the District Court’s denial of summary judgment in a case where corrections officers “gratuitously beat” a pretrial detainee. Jacobs got into a fight with another inmate at Cumberland County Jail. Several minutes after the fight, a group of corrections officers forcibly removed Jacobs from the dorm. Jacobs sued, and the officers moved for summary judgment on the ground of qualified immunity. After reviewing the record, including a security video, the District Court denied the motion. The Third Circuit’s review involved a qualified-immunity analysis, which consisted of two questions: (1) whether the facts showed the officers violated a constitutional right, and (2) whether the right was clearly established, such that it would have been clear to a reasonable officer that their conduct was unlawful. First, the Court found that a reasonable jury could find that the officers used objectively unreasonable force. Second, the Court had “no difficulty concluding that the unlawfulness of the officers’ conduct was beyond debate.”

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