Angola guards cleared of excessive force for pepper spraying | Courts

Two Angola guards who handcuffed an inmate through his cell bars and then pepper-sprayed him did not break the law in the course of their duties, a federal appeals court ruled. 

Angola inmate Alvin Williams sued two correctional officials, Captain David Voorhies and Lieutenant Omar Walker, in November 2021 on excessive force grounds over the pepper-spraying. 

Williams claimed that on the morning of April 28, 2021, he asked officers, Voorhies and Walker, to be given mental health assistance because he was “high” in his cell and “feared for his life.”

Voorhies ordered Williams to put his hands through the bars so he could be handcuffed, and Williams complied. Then, Walker attempted to pepper-spray Williams, succeeding on the second attempt.

Williams further claims that Voorhies walked him into a wall after taking him out of the cell and moving into a stairwell, while he was handcuffed and blinded by the spray. He also claims Voorhies purposefully pressed him against the wall, giving his hand a stress fracture from where it was pressed.

A doctor found Williams’ right hand was swollen days later, court records say, but no evaluation revealed a fracture or break in Williams’ hand.

When Williams’ suit was first before a lower court, a judge denied Voorhies’ and Walker’s motions for summary judgment, which they sought on the grounds of qualified immunity as officers acting in the line of duty.

The judge’s denial was due to believing Williams had a claim of excessive force against Voorhies for the stairwell incident and a claim of failure-to-intervene against Walker.

The Fifth Circuit Court of Appeals reversed those rulings on May 8, dismissing Williams’ claims against both officers on qualified immunity grounds.

In the three-judge panel’s reasoning, they say that the several cases Williams cites in his argument aren’t relevant to what Williams experienced.

In one, the prisoner who claimed excessive force had been beaten by a “swarm” of guards, which is “worlds apart” from what happened to Williams, the panel said.

Judge Dana Douglas offered the only dissent to the ruling.

“Alvin Williams called out for help while suffering a drug-induced mental health episode. Instead of help, though, he was met with the spray of a chemical agent, while restrained, and was further subjected to unnecessary force, in violation of our circuit’s clearly established law,” Douglas said in her dissent.

She continued that since Williams was sprayed only after he’d already been handcuffed through the bars of his cell, he was no longer a threat at the time of the pepper-spraying.