Angel v. Cruse

Randall Angel, then an inmate, filed a civil rights complaint against corrections officer Michael Cruse, in his individual capacity, alleging that Cruse violated his civil rights by filing a disciplinary charge against him and by having him placed in administrative segregation in retaliation for Angel’s attempt to file a grievance against Cruse. The district court granted summary judgment to Cruse, finding that the evidence demonstrated that Angel had actually threatened Cruse, and in the alternative, Cruse was entitled to qualified immunity because he could not have known that the adverse action violated Angel’s constitutional rights. The Supreme Court reversed, holding that genuine issues of material fact existed with regard to each of the disputed elements of the retaliation claim and with regard to Cruse’s entitlement to qualified immunity. Remanded. View "Angel v. Cruse" on Justia Law