Published on: Monday, February 8, 2021

A federal court has ruled yet again that shackling an inmate in full restraints while exercising qualifies as cruel and unusual punishment, and that a warden who allegedly flouted that rule is not protected by qualified immunity.

The U.S. Court of Appeals for the Second Circuit held that Angel Quiros, former warden at the Northern Correctional Institute in Somers, Connecticut, violated M.A. Edwards's Eighth Amendment rights when prison officials placed Edwards in restraints during his exercise time over a six-month period. Specifically, Edwards had his "hands cuffed," with "leg irons on [his] ankles" and "a chain tether securing those two sets of restraints to one another."

The jury found that the prison warden had denied the plaintiff his Eighth Amendment rights in knowingly allowing him to "exercise" in full body restraints for six months such that the inmate was not able to exercise at all. The trial judge vacated the verdict, but the Court of Appeals reinstated the jury verdict, determining the jury had a basis to find the warden was aware of the civil rights violation.

The case is Edwards v. Quiros, et al., No. 19-3251 (2d Cir. Jan. 27, 2021). The oral argument is at this link.