An African-American inmate at Corcoran State Prison won reinstatement of his civil rights claims for injuries after violent incidents involving inmates and guards resulted in a race-based lockdown of black inmates.
The 9th U.S. Circuit Court of Appeals Thursday held Garrick Harrington was entitled to a new trial on his claim Equal Protection Clause claim for the race-based lockdown.
The court denied a second claim of cruel and unusual punishment under the Eighth Amendment for an injury he suffered during escort to a shower during the emergency restrictions.
Harrington was not involved in the violence or gang activity that sparked the lockdown, the court said.
The court held that jury instructions did not adhere to a requirement that prison officials be held to a higher legal standard to demonstrate that the race-based action was narrowly tailored. The appeals court found the jury instructions prejudicial against Harrington.
Harrington’s lawsuit stems from a 2004 period when five violent incidents rocked the prison involving black inmates associated with gangs, according to the court. The incidents included riots involving white inmates and others associated with “disruptive groups” that engage in coordinated aggressive actions, the court said.
There was also information that some inmates planned to attack prison staff. In response, the prison imposed a lockdown of African-American inmates based on “multiple batteries on staff by blacks,” the court said.
The court found Harrington had a claim for violation of Equal Protection rights based on the race-based lockdown of black inmates.
The court said that while prison interests in security may figure into an analysis of equal protection, they do not excuse the narrow tailoring requirement of a limited infringement of Harrington’s rights.
During the lockdown while inmates were escorted to showers, Harrington slipped and fell, injuring his back. Despite treatments, his pain continues and requires medication, the court said. But the appeals court upheld the jury verdict that his Eighth Amendment rights were not violated.
Case: Harrington v. Scribner, No. 09-16951