Patterson v. Kintu
- David Doty
- 0:17-cv-02263
- U.S. District Court · District of Minnesota
- 3
In Patterson v. Kintu, Judge Doty overruled Patterson’s objections, granted defendants’ summary-judgment motion, and dismissed the excessive-force case with prejudice.
The ruling resolved Honora Tremaine Patterson’s excessive-force claims against the defendants by granting their motion for summary judgment and dismissing the matter with prejudice.
What happened
In Patterson v. Kintu, Honora Tremaine Patterson, who represented himself, brought an excessive-force case under a federal civil-rights law. The opinion says the case’s background was fully described in the magistrate judge’s report and recommendation, so the district court did not repeat it.
Patterson objected to the recommendation that defendants receive summary judgment, arguing that the magistrate judge was biased and made false factual findings. The district court rejected those arguments, finding that the magistrate judge properly applied the summary-judgment standard and relied on facts in the record.
Judge David S. Doty overruled Patterson’s objections, adopted the report and recommendation in its entirety, granted defendants’ motion for summary judgment, and dismissed the matter with prejudice.
The detailed version
- Patterson v. Kintu · No. 0:17-cv-02263
- David Doty
- Feb. 27, 2019
Background
Honora Tremaine Patterson, proceeding without a lawyer, brought an excessive-force claim under 42 U.S.C. § 1983, a federal civil-rights statute. The court stated that the report and recommendation by Magistrate Judge Becky R. Thorson fully set out the case’s background and therefore did not repeat it.
Patterson objected to the magistrate judge’s recommendation that the defendants’ motion for summary judgment be granted and that Patterson’s claims be dismissed with prejudice. Patterson argued that the magistrate judge showed bias and favoritism toward the defendants and made false factual findings in their favor.
Court’s analysis
The district court reviewed the objections and the report and recommendation anew, as required for objections to a magistrate judge’s recommendation. For an excessive-force claim under § 1983, the court explained that Patterson had to show that the force was not used in a good-faith effort to maintain or restore discipline, or that it was used maliciously and sadistically for the purpose of causing harm.
Patterson argued that the magistrate judge was biased because the report and recommendation mentioned Patterson’s extensive prison disciplinary record. The district court concluded that the record was cited to show that prison officials reasonably believed the force used to secure Patterson’s cell was necessary and was administered in a good-faith effort to maintain or restore discipline.
Patterson also argued that the magistrate judge relied on false factual statements and failed to view the facts in the light most favorable to Patterson, who was opposing summary judgment. The district court disagreed, finding that the magistrate judge applied the proper summary-judgment standard and relied on facts in the record rather than unsupported allegations, conclusory statements, or statements contradicted by the record.
Disposition
The court adopted the report and recommendation in its entirety. It overruled Patterson’s objections, granted defendants’ motion for summary judgment, and dismissed the matter with prejudice. The order was signed by Judge David S. Doty.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.