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La. corrections officers granted qualified immunity in pepper spray case

An inmate alleged he was pepper-sprayed while restrained and injured during an escort following a mental health crisis

Louisiana State Penitentiary

Louisiana DOC

By Quinn Coffman
The Advocate, Baton Rouge, La.

ANGOLA, La. — Two Angola guards who handcuffed an inmate through his cell bars and then pepper-sprayed him did not break the law in the course of their duties, a federal appeals court ruled.

Inmate Alvin Williams sued two correctional officials, Capt. David Voorhies and Lt. Omar Walker, in November 2021 on grounds of excessive force over the pepper-spraying.

Williams claimed that on the morning of April 28, 2021, he asked Voorhies and Walker to be given mental health assistance because he was “high” in his cell and “feared for his life.”

Voorhies ordered Williams to put his hands through the bars so he could be handcuffed, and Williams complied. Then, Walker attempted to pepper-spray Williams, succeeding on the second attempt.

Williams further claimed that while he was handcuffed and blinded by the spray, Voorhies walked him into a wall after taking him out of the cell and moving into a stairwell. He also claims Voorhies purposefully pressed him against the wall, giving his hand a stress fracture from where it was pressed.

A doctor found Williams’ right hand was swollen days later, court records say, but no evaluation revealed a fracture or break in Williams’ hand.

When Williams’ suit was first before a lower court, a judge denied Voorhies’ and Walker’s motions for summary judgment, which they sought on the grounds of qualified immunity as officers acting in the line of duty.

The judge’s denial was due to believing Williams had a claim of excessive force against Voorhies for the stairwell incident and a claim of failure-to-intervene against Walker.

The Fifth Circuit Court of Appeals reversed those rulings on May 8, dismissing Williams’ claims against both officers on qualified immunity grounds.

In the three-judge panel’s reasoning, they say that the several cases Williams cites in his argument aren’t relevant to what Williams experienced.

In one, the prisoner who claimed excessive force had been beaten by a “swarm” of guards, which is “worlds apart” from what happened to Williams, the panel said.

Judge Dana Douglas offered a dissent to the ruling.

” Alvin Williams called out for help while suffering a drug-induced mental health episode. Instead of help, though, he was met with the spray of a chemical agent, while restrained, and was further subjected to unnecessary force, in violation of our circuit’s clearly established law,” Douglas said in her dissent.

She continued that since Williams was sprayed only after he already had been handcuffed through the bars of his cell, he was no longer a threat at the time of the pepper-spraying.

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© 2026 The Advocate, Baton Rouge, La. Visit www.theadvocate.com. Distributed by Tribune Content Agency, LLC.

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