Hope v. Pelzer

Facts

Alabama was the only State that followed the practice of chaining inmates to one another in work squads. It was also the only State that handcuffed prisoners to 'hitching posts' if they either refused to work or otherwise disrupted work squads. While P was working in a chain gang near an interstate highway, he got into an argument with another inmate. Both men were handcuffed to a hitching post. P was released two hours later after the guard captain determined that the altercation had been caused by the other inmate. P was offered drinking water and a bathroom break every 15 minutes, and his responses to these offers were recorded on an activity log. His arms were above shoulder height and P grew tired from being handcuffed so high. Whenever he tried moving his arms to improve his circulation, the handcuffs cut into his wrists, causing pain and discomfort. Some days later P got into a wrestling match with a guard. Four other guards intervened, subdued P, handcuffed him, placed him in leg irons and eventually he was put on the hitching post. The guards made him take off his shirt, and he remained shirtless all day while the sun burned his skin. P remained there for 7 hours. He was given water only once or twice and was given no bathroom breaks. A guard taunted P about his thirst. Hope filed suit under §1983, in the District Court. The case was referred to a Magistrate Judge who treated the responsive affidavits filed by Ds as a motion for summary judgment. The Magistrate concluded that the guards were entitled to qualified immunity. The District Court entered judgment for Ds. The Court of Appeals affirmed. It held that the use of the hitching post for punitive purposes violated the Eighth Amendment. The court then concluded that the facts in the two precedents on which P primarily relied were not ''materially similar' to P's situation.'' P appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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