BRENT JAMES NASH v. AUSTIN BRYCE and CALVIN TURNER, Correctional Officers, in their official and personal capacities - Articles

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BRENT JAMES NASH v. AUSTIN BRYCE and CALVIN TURNER, Correctional Officers, in their official and personal capacities

Posted by: Azya Thornton on Sep 30, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Zachary T. Runyan, RUNYAN LAW GROUP, Saint Clair Shores, Michigan, for Appellant.

Attorneys 2: ARGUED: Christopher Alex, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee..

Attorneys 3: ON BRIEF: Zachary T. Runyan, RUNYAN LAW GROUP, Saint Clair Shores, Michigan, for Appellant.

Attorneys 4: ON BRIEF: James E. Keathley, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee.

Judge(s): GILMAN, READLER, and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

BLOOMEKATZ, Circuit Judge. Two corrections officers, Austin Bryce and Calvin Turner, escorted prisoner Brent Nash through a prison hallway and out into a prison yard. Upon entering the prison yard, the officers executed a takedown maneuver on Nash, throwing him to the cement and fracturing his foot in two places in the process. This appeal centers on whether that takedown maneuver was justified. Nash contends that he did nothing prior to the takedown to warrant the officers’ use of force against him. The officers contend that Nash lunged away from them, causing them to panic and take him to the ground. Most of the relevant events were captured on the prison’s security videos. Relying on that video footage, a prison misconduct hearing officer found that Nash had assaulted Bryce and Turner by lunging away from them before their decision to take him down. Nash then filed suit against Bryce and Turner under 42 U.S.C. § 1983, arguing that the takedown violated his Eighth Amendment right to be free from excessive force. After discovery, the district court granted summary judgment to the defendants, holding that they were entitled to qualified immunity. In so doing, the district court made two conclusions about the factual record—that the hearing officer’s factual findings from the prison misconduct hearing should have preclusive effect on the litigation, and that the prison videos blatantly contradicted Nash’s testimony. We disagree with both conclusions and, relying on a corrected review of the factual record, hold that Nash has raised a genuine dispute of material fact regarding whether Bryce and Turner violated his Eighth Amendment rights. We accordingly reverse the district court’s grant of summary judgment to the officers.

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