Opinion

Valladolid

Court
District Court, E.D. California
Filed
Jul 10, 2026
Cited by
0 cases
Authority
More cited than 42.1%

The opinion

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7 UNITED STATES DISTRICT COURT

8 EASTERN DISTRICT OF CALIFORNIA

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10 MUJAAHID F. HARRIS, Case No.: 1:23-cv-01502 JLT EPG (PC)

11 Plaintiff,

ORDER ADOPTING FINDINGS AND

12 v. RECOMMENDATIONS TO DENY

DEFENDANTS’ MOTION FOR SUMMARY

13 O. VALLADOLID, et al., JUDGMENT

14 Defendants. (Docs. 79, 94)

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16 Plaintiff seeks to hold defendants liable for violations of his civil rights. This matter was

17 referred to a United States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule

18 302. The magistrate judge issued findings and recommendations to deny Defendants’ summary

19 judgment motion. (Doc. 94.) Defendants objected to the findings and recommendations (Doc.

20 95) and plaintiff responded to defendants’ objections (Doc. 96). The Court has renewed the

21 matter de novo.

22 The Findings and Recommendations are supported by the record and proper analysis.

23 When the evidence is taken in the light most favorable to plaintiff, as it must be at this stage, it

24 would permit a reasonable jury to decide that the defendant officers acted maliciously and failed

25 to intervene in violation of the Eighth Amendment. (Doc. 94 at 18–19); see also Hudson v.

26 McMillian, 503 U.S. 1, 6–7 (1992) (discussing relevant legal standards); Whitley v. Albers, 475

27 U.S. 312, 320–21 (1986) (same); Bearchild v. Cobban, 947 F.3d 1130, 1140–41 (9th Cir. 2020)

(same).

1 The officers rely heavily on the argument that their actions were a constitutional attempt

2 to secure plaintiff’s compliance with their orders. (See, e.g., Doc. 95 at 4.) They argue similarly

3 that his refusal to comply created an “emergency” that justified additional force. (See id.) These

4 arguments assume their own conclusions. Plaintiff is exempted from behind-the-back

5 handcuffing because of a previous injury. That much is undisputed. And yet, in the officers’

6 telling, plaintiff’s reliance on this exemption is both the reason they were justified in forcing his

7 hands behind his back and the source of the “emergency” that justifies their decision to force his

8 hands behind his back. (See id. at 3–5.)

9 In any event, a jury could reasonably find that plaintiff was exempt from behind-the-back

10 handcuffing; that he told the officers about this exemption; that there was no reason for them to

11 disbelieve him; that he refused to put his hands at his sides or behind his back because he was

12 physically unable to do so; and that the officers nevertheless demanded his compliance and forced

13 him to comply, exacerbating his injury. (See Doc. 94 at 18–19.) A jury could also reasonably

14 decide that the officers had plaintiff firmly under their control, such that there was no

15 “emergency.” He was prone on the ground, where several officers were holding him. (See id. at

16 18.) It would be reasonable to find that he posed no danger to anyone. (See id.) These findings

17 would permit a reasonable jury to find that the defendants violated the Eighth Amendment by

18 acting maliciously and with an intent to cause harm and not in a good faith attempt to maintain

19 order.

20 The magistrate judge correctly recommends denying summary judgment despite the

21 officers’ assertion of qualified immunity as well. The Court must take the evidence in the light

22 most favorable to plaintiff, including when it determines whether the relevant law was clearly

23 established. Tolan v. Cotton, 572 U.S. 650, 656–57 (2014); Martinez v. Stanford, 323 F.3d 1178,

24 1184 (9th Cir. 2003). Taking the evidence in that light would show the officers acted maliciously

25 and intended to harm plaintiff by forcing his hands behind his back, as summarized above.

26 “Since 1992, the legal standard articulated in Hudson has provided officers with ample notice that

27 malicious or sadistic use of force is unlawful.” Alexander v. Perez, 124 F. App’x 525, 526 (9th

1 } (9th Cir. 2019) (unpublished) (same); Fugawa v. Dearmond, 718 F. App’x 550, 551 (9th Cir.

2 | 2018) (unpublished) (same); Covington v. Fairman, 123 F. App’x 738, 741 (9th Cir. 2004)

3 | (unpublished) (same); Martinez, 323 F.3d at 1183 (same); see also Hoard v. Hartman, 904 F.3d

4 | 780, 790 (9th Cir. 2018) (colleting authority). The “gratuitous infliction of punishment is

5 | unconstitutional, even in the prison context.” Hope v. Pelzer, 536 U.S. 730, 748 (2002). That is

6 | true “even in novel factual circumstances.” /d. at 741. An officer is not entitled to qualified

7 | immunity at summary judgment if, under a reasonable interpretation of the evidence, “any

8 || reasonable officer should have realized that [his actions] offended the Constitution.” Taylor v.

9 | Riojas, 592 U.S. 7, 9 (2020) (per curiam). That would be the situation here, assuming a jury

10 | accepted plaintiffs version of the events.

11 The officers are of course entitled to an opportunity to prove that they acted reasonably

12 | and that plaintiff is not to be trusted, but they must do this at trial. See, e.g., Weldeyohannes v.

13 | Washington, 162 F.4th 972, 978-79 (9th Cir. 2025) (reversing grant of qualified immunity in

14 | prison use-of-force dispute “because factual disputes remain about the [defendants’] conduct that

15 || may impact whether the unlawfulness was clearly established at the time” (citation and quotation

16 | marks omitted)).

17 Accordingly, the Court ORDERS:

18 1. The Findings and Recommendations issued April 17, 2026 (Doc. 94) are ADOPTED

19 in full.

20 2. Defendants’ motion for summary judgment (Doc. 79) is DENIED.

21 3. This matter is referred back to the assigned magistrate judge.

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23 | IT IS SO ORDERED.

Dated: _July 10, 2026_ ears [Tourn

25 TED STATES DISTRICT JUDGE

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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