Civil rights judgment for woman whose arms and legs were shackled during labor is reversed
Juana Villegas sued Tennessee police authorites under 42 USC 1983 and the Eighth Amendment, arguing that they violated her civil rights when she was handcuffed before and after the birth of her child and then denied a breast pump. Villegas was arrested in 2008 after she was stopped by a State Trooper and could not produce a valid drivers license. She was nine months pregnant when she was detained and authoritites determined that she was an illegal immigrant.
Unable to post bond, Villegas was identified as a medium securtiy prisoner. Her water broke two days later. She was then handcuffed and her legs were shackled together, and she was transported by ambulance to the hospital. Hospital staff demanded the removal of the shackles so that Villegas could be gowned, however, she was immediately shackled again. When a female officer arrived to replace the transporting officers, she removed the wrist and leg shackles, but shackled Villegas to the hospital bed.
Although the woman officer admitted she "overheard" the hospital staff discussing a medical "No Restraint Order," she claimed that no hospital representative ever informed her that the bed restraint should be removed. She did admit discussing the need to remove "leg irons" with nursing staff.
Ultimately, Villegas' shackles were removed long enough to deliver her child and then replaced. When the hospital staff provided her with a breast pump to relieve breast congestion, it was confiscated by the authorities. Villegas ultimately secured legal representation and filed a lawsuit against the police authorities, arguing that unreasonable restraint procedures and the denial of the breast pump constituted unwarranted "cruel and unusual punishment."
After hearing the facts, the trial judge granted summary disposition to the pregnant woman, finding that the Tennessee officers had violated clearly established law in a manner that perpetrated unusual and unnecessary punishment on Villegas. A majority of the Sixth Circuit Court of Appeals overturned this decision and sent the case back to the trial judge for further factual review. The higher court's majority deemed the evidence inadequate to support a summary disposition, particularly with regard to whether the officers clearly understood their duties. Judge White wrote a strongly-worded dissent.