The first set of claims relate to Excessive Force used by five jail employees. They are identified as Sergeant Quest, Deputy Maynes, Deputy Anda, Deputy Green, and Deputy Powell. According to Plaintiff, these five defendants beat him in his cell despite his compliance with orders. Plaintiff alleged that he was punched, stomped on, dragged to the floor, and hit multiple times. Plaintiff further alleged that one of the defendants, specifically Sergeant Quest, ordered the beating in his cell.
The second set of claims are for Failure to Intervene against the previously mentioned jail employees. This claim alleges that those five defendants, who applied force in Plaintiff’s cell, failed to take reasonable steps to protect him from excessive force by instead participating in the beating.
Plaintiff raised a claim of Retaliation against Sergeant Quest. According to Plaintiff, Sergeant Quest relocated him to a windowless cell because Plaintiff filed a grievance and requested medical attention after being beaten. Plaintiff alleged that Sergeant Quest “intercepted” the attempt at grieving or seeking medical attention. Replacement was ordered, as Plaintiff alleges, to prevent officials from seeing or documenting Plaintiff’s injuries. At the pleading stage, this Court drew an inference that placement in a windowless cell may have been ordered as an attempt to hinder Plaintiff’s ability to substantiate legal claims.While relocated, the replacement allegedly prevented Plaintiff from receiving medical treatment for fifteen days.
As to his final claim, Plaintiff raised a claim of deliberate indifference to serious medical needs against Nurse Henri. According to these allegations, Nurse Henri failed to provide emergency medical services and failed to provide treatment after the beating. The allegations also state that Nurse Henri did not write an event report after the beating. As injuries, Plaintiff states that he endured a concussion, broken ribs, and cuts, bleeding, and swelling to his head and face. Plaintiff adds that he now suffers from blurred vision, headaches, and panic attacks that range in their severity. If interested, please email FLSD_ProBono@flsd.uscourts.gov
