Lombardo v. City of St. Louis, Mo.

Court grant cert and remands case for reconsideration of facts and circumstances that may have rendered force excessive; pretrial detainee who had apparently attempted suicide and then struggled with officers was placed in handcuffs and leg irons and placed in prone position, held face down on floor of cell with at least one officer applying pressure to his back for fifteen minutes until he stopped moving and lost a pulse; Supreme Court says unclear if Eighth Circuit would say prone restraint is not objectively unreasonable and per se constitutional when subject actively resists; Eighth Circuit should have taken into account officer training that prone restraint can cause suffocation, that subject should be taken off stomach as soon as he is handcuffed, that subject’s struggling may be due to oxygen deficiency rather than desire to disobey, duration of the restraint, and fact that prisoner was handcuffed and leg shackled.