Taylor v. Murphy
Requiring an inmate to remain in handcuffs, with hands behind the back, during recreation periods does not constitute cruel and unusual punishment, in violation of the Eighth Amendment. The plaintiff, Derrick Taylor, brought a civil-rights action alleging that he was denied a meaningful opportunity to exercise, because the Department of Correction required that certain inmates at Northern Correctional Institute, a maximum security level institution, wear handcuffs, with hands behind their backs, during recreation periods. Taylor, a leader of the Latin Kings gang who was convicted of murder and sentenced to 80 years, was identified as an inmate who belongs to a gang or who presents a risk to the general prison population. Previously, Taylor hid a loaded gun in a prison in New Jersey and pled guilty to possession of the gun. Taylor also was disciplined for possession of contraband, because he had several pieces of metal, a screw and a wire, which could be used to make homemade knives or to start a fire. On Jan. 6, 2010, inmates whose hands were handcuffed in front struck DOC workers on their heads with the handcuffs. On January 14, the DOC required that inmates' hands be handcuffed behind their backs. The DOC argued that Taylor, who is housed in a single cell that is 7 by 12 feet, had enough room to run in place, and to perform jumping jacks, squat thrusts, sit-ups and push-ups. Taylor testified that he can perform about 200 push-ups per day in his cell. An inmate testified that inmates perform group exercises, with one inmate calling out the exercise and the other inmates performing in unison. Taylor did not present evidence that other inmates retaliate against inmates who exercise in their cells. Taylor's expert, Douglas Baumgarten, reported that an inmate can walk 3.5 miles per hour, even with the inmate's hands behind his back. The court credited the testimony of the DOC's expert, Dr. Ducate, that Taylor possessed a meaningful opportunity to exercise, and that there was no evidence exercising in handcuffs caused physical or mental injury to Taylor. The court granted judgment to the defendants.