Scott v. Garcia
- Haywood Gilliam
- 4:25-cv-00435
- U.S. District Court · Northern District of California
- 8
In James Scott v. R. Garcia, Judge Gilliam granted Garcia summary judgment, finding video showed reasonable force during handcuffing and no Eighth Amendment violation.
James Scott’s civil-rights claim against correctional officer R. Garcia was resolved in Garcia’s favor, and the case was closed.
What happened
In James Scott v. R. Garcia, James Scott, representing himself, claimed that correctional officer R. Garcia used excessive force against him at Salinas Valley State Prison on August 28, 2024. Scott alleged that Garcia put him in a chokehold, dragged him down, and slammed his head into the ground after Scott refused to be handcuffed.
Garcia asked the court to grant summary judgment, which ends a case when the evidence shows that no reasonable jury could find for the opposing party. Scott did not oppose the motion. The court reviewed video footage showing that Scott refused orders, physically resisted attempts to handcuff him, and that Garcia used force to subdue him. The court found that the video contradicted Scott’s account.
Judge Haywood S. Gilliam, Jr. granted Garcia’s motion for summary judgment, ruling that Garcia used reasonable force in a good-faith effort to restore discipline and did not violate Scott’s constitutional rights. The court also found Scott’s request to compel additional discovery moot and ordered the case closed.
The detailed version
- Scott v. Garcia · No. 4:25-cv-00435
- Haywood Gilliam
- Dec. 17, 2025
Background
James Scott filed a civil-rights action under 42 U.S.C. § 1983, alleging that Salinas Valley State Prison correctional officer R. Garcia used excessive force against him in violation of the Eighth Amendment. Scott alleged that, on August 28, 2024, Garcia attempted to grab him, put an arm around his neck, placed him in a chokehold, dragged him to the ground, and slammed his head into the ground.
The record showed that prison officers had ordered Scott to return to his housing unit and later ordered him to place his hands behind his back to be handcuffed. Scott refused to submit to handcuffing. The parties disagreed about what happened during the ensuing struggle. Scott did not oppose Garcia’s motion for summary judgment.
Summary-Judgment Standard
Summary judgment is appropriate when the evidence shows that there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The court ordinarily views disputed evidence in the light most favorable to the nonmoving party. But when video footage plainly contradicts one party’s account, the court may rely on what the video depicts.
Court’s Analysis
The court found that Scott had not disputed the accuracy or authenticity of the video footage. It concluded that the video showed Scott refusing orders to return to his housing unit and to be handcuffed, physically resisting the officers’ efforts to handcuff him, and grabbing the exercise-bar frame. The court also found that the video showed Garcia using reasonable force to place Scott in handcuffs.
The court determined that Garcia did not place Scott in a chokehold, drag him to the ground, or slam his head into the ground. It ruled that Garcia used force in a good-faith effort to maintain and restore discipline and used only the force necessary to handcuff Scott. The court therefore found no Eighth Amendment violation.
Qualified Immunity
The court also discussed qualified immunity, a legal protection that can shield government officials from being required to stand trial for reasonable conduct. Because the court found no constitutional violation, it concluded that no further qualified-immunity analysis was necessary.
Discovery Request and Disposition
About eleven months after discovery began and four months after Garcia filed the summary-judgment motion, Scott filed a request titled “Motion to Compel.” He sought to depose an unnamed institutional officer and require that officer to produce videos of the incident. The court found that request moot because it granted summary judgment for Garcia. The court noted that Garcia had sworn that Scott had received all videos of the incident and that Scott had offered no evidence that Garcia withheld relevant evidence.
The court GRANTED Garcia’s motion for summary judgment, found the discovery request moot, terminated Docket Nos. 13 and 24, and closed the case.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.