The Court of Appeals for Fourth Circuit ruled Monday in favor of North Carolina inmate Willie James Dean, Jr. in a prison abuse case, finding corrections officers were not entitled to qualified immunity.

Dean alleged that corrections officers had used excessive force against him in violation of the Eighth Amendment. The district court that heard the case granted summary judgment for the officers, holding that a reasonable jury would determine that the incidents at issue were appropriate uses of force, but the appeals court reversed that decision Monday.

The two incidents arose after Dean head-butted officers. In the first incident, he head-butted an officer taking him back to his cell, and the “officer retaliated by pepper-spraying his face while he was subdued and lying on his back in handcuffs.” After a second incident in which Dean head-butted an officer, “a second officer responded … by pushing Dean into a closet where multiple officers kicked and punched him while he lay on the ground with his hands cuffed behind him.”

The district court stated that such responses by the officers were “necessary to protect officer safety” and that they were “proportionate to the threat posed by Dean.” In holding that a reasonable jury would find this to have been the case, it granted summary judgment to the officers.

The Fourth Circuit, however, held that they were required to consider the motive of the officers in applying such force, and a reasonable jury could find either that the officers used force to protect themselves or to retaliate against Dean. Because a jury could find for either party, the Fourth Circuit held that summary judgment was inappropriate.

The court also noted that the injuries Dean sustained were severe, including abrasions and contusions on his face, a closed fracture of his nasal bone, and a subconjunctival hematoma. He had surgery to remove a cyst near his fracture following the incidents, and “[w]hen he filed the complaint in this action, Dean still was suffering from blurred vision, dizzy spells, and light sensitivity, among other ailments.”