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Criminal Law Keyed to Capers
Young v. Martin
Citation:
801 F.3d 172 (3d Cir. 2015)Facts
On the evening of September 20, 2009, while Young was confined in the RHU at State Correctional Institution, his cell door was mistakenly unlocked and left open by a Corrections Officer (“CO”) in the control room. He exited his cell but was soon captured by the COs. As the COs escorted him to the stairs, Young passively refused to walk by laying down on the ground. After the COs carried Young to a nearby corridor and placed him face down on the ground with his hands and ankles cuffed, four COs stood over him and further restrained his limbs. Young remained motionless on the ground and did not struggle during this process. However, rather than asking Young to submit to a routine strip search and although he had not spit on anyone, the COs placed a spit mask on him and cut off Young’s clothes to perform a prone strip search. Young complained but did not physically resist the search; no contraband was found.After the search was complete, Young, naked, cuffed, and compliant, was hoisted to his knees and photographed for several minutes to record any injuries he may have sustained during the incident. His legs were so numb that he could not walk, and he had to be wheeled back to the RHU in the chair. As Defendants’ counsel conceded at oral argument, there is no evidence in the record that anyone provided the requisite authorization to exceed the prison’s eight-hour maximum.
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Criminal Law