Brown v. Ramsey
United States District Court for the Eastern District of Virginia
121 F. Supp. 2d 911 (2000)
- Written by Tammy Boggs, JD
Facts
Daniel Brown (plaintiff) was a first-grade student who suffered from a high-functioning form of autism. Daniel’s special-education teacher, Natalie Ramsey (defendant) and Ramsey’s teaching assistant, Ruby Hart (defendant) were trained to use and occasionally employed a “basket hold” restraint on Daniel, which involved holding his wrists and crossing his hands in front of his chest. According to Daniel, his teachers used the restraint, and pushed Daniel’s head down, if Daniel misbehaved or for some other reason had to be put in a “time-out.” The use of force would end when Daniel quieted down and stopped crying. According to Ramsey and Hart, they only used the hold a handful of times when Daniel became dangerous to himself or others. Daniel claimed to experience pain and a choking sensation during the restraints but never sought medical attention. Daniel also claimed to have suffered posttraumatic stress disorder from the alleged abuse. Daniel and his father, Kevin Brown (plaintiff) sued Ramsey and Hart, among others, alleging a constitutional violation based on Daniel’s substantive-due-process rights. The Browns claimed that Daniel’s teachers resented Daniel’s presence in the classroom. Ramsey and Hart filed a motion for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Doumar, J.)
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