Braun v. D.O.C.

Background

Nathan Christopher Braun, who was incarcerated at Minnesota Correctional Facility–Faribault when the events occurred, sued employees of the Minnesota Department of Corrections under 42 U.S.C. § 1983. He alleged that, during a November 6, 2018 cell transfer, the defendants used excessive force and caused multiple injuries. He also alleged that they were deliberately indifferent to his serious medical needs after the transfer.

Braun sought monetary damages and other relief. The court had previously dismissed his requests for injunctive relief and for the initiation of criminal and civil charges, but allowed his individual-capacity constitutional claims to continue. The remaining claims concerned excessive force and deliberate indifference to medical needs.

The defendants argued that Braun had resisted orders concerning handcuffs after throwing a food tray and yelling at a correctional officer. They maintained that chemical irritant, joint manipulation, and restraints were necessary, that Braun was not pushed down the stairs, and that he was offered a medical assessment.

Summary-judgment standard and objections

The magistrate judge recommended granting summary judgment for the defendants. Summary judgment is granted when the evidence does not show a genuine dispute of material fact requiring a trial. Braun objected to the recommendation and argued, among other things, that he lacked appointed counsel, that the video recordings had been wrongly interpreted, and that the evidence supported his claims of nerve damage and facial scarring.

The court overruled Braun’s objection concerning counsel. Although the court construed his filings liberally because he was representing himself, it held that his lack of counsel did not remove his obligation to produce evidence opposing summary judgment.

The court also overruled his objection concerning the video recordings. It concluded that the videos contradicted important parts of Braun’s account, including his assertion that he was completely compliant and his allegation that officers threw him down the stairs. Because the videos directly contradicted those assertions, the court treated the events shown in the recordings as undisputed.

The court found that Braun had not submitted evidence establishing that the incident caused nerve damage or facial scarring. It stated that an excessive-force claim turns on whether the force was used in good faith and was appropriate, rather than solely on the injury sustained. After reviewing the record and videos, the court agreed that the defendants used an appropriate level of force.

The court rejected Braun’s argument that alleged violations of Minnesota Department of Corrections policies created liability under federal law. It explained that § 1983 does not make state officials liable merely because they violated state corrections policies.

For the medical-care claim, Braun disputed whether he had refused a medical assessment, arguing that he had refused only medication. The court said that dispute was not material because other evidence supported the conclusion that the defendants had not deliberately disregarded a serious medical need. The court relied on video showing that health-services staff determined Braun was breathing and talking, and it concluded that the marks and abrasions shown in the evidence did not establish an objectively serious medical need. The court also found that Braun had not produced evidence supporting his alleged nerve damage beyond records documenting his complaints of pain and medication.

Disposition

After conducting a de novo review of the portions of the recommendation to which Braun objected, Judge Joan N. Ericksen accepted the magistrate judge’s conclusions. The court granted the defendants’ motion for summary judgment and dismissed with prejudice Braun’s amended complaint. Judgment was ordered to be entered accordingly.