Victor Hill: Federal Appeals Court rejects ex-sheriff's appeal
CLAYTON COUNTY, Ga. - The 11th U.S. Circuit Court of Appeals in Atlanta has rejected former Clayton County Sheriff Victor Hill's appeal of his October 2022 conviction for violating the civil rights of inmates.
Hill, who was in charge of the Clayton County Jail, faced accusations of ordering detainees—some of whom were neither violent nor uncontrollable—into restraint chairs for extended periods without necessary bathroom breaks. The court noted that each detainee subjected to this treatment sustained injuries ranging from open wounds to lasting scars and nerve damage.
Hill contested his conviction on three grounds. Firstly, he argued that he lacked fair warning that his actions were unconstitutional. Secondly, he claimed that the district court mishandled juror misconduct inquiries and jury instructions. Lastly, he contended that the government failed to present sufficient evidence regarding the punitive nature of his conduct and its effects on the detainees.
In their ruling, the Appeals Court wrote, "We reject each one. First, Hill had fair warning that his conduct was unconstitutional—that is, that he could not use gratuitous force against a compliant, nonresistant detainee. Second, sufficient evidence supported the jury’s conclusion that Hill’s conduct had no legitimate nonpunitive purpose, was willful, and caused the detainees’ injuries. Third, the district court did not coerce the jury verdict but properly exercised its discretion in investigating and responding to alleged juror misconduct."
U.S. Circuit Judges Kevin Newsom, Robin Rosenbaum, and Stanley Marcus reaffirmed that established case law clearly prohibits the excessive use of force on compliant, nonresistant detainees.
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Hill, who served as sheriff of Clayton County during two separate periods, introduced the use of restraint chairs in 2018. He had implemented a policy specifying that detainees exhibiting "actual violence" should first be placed in isolation, with restraint being a last resort.
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Following his conviction, Hill began serving an 18-month sentence at the Forrest City Federal Correctional Institution in Arkansas on May 15, 2023. He was released after serving less than a year in March, transitioning to community confinement under the supervision of the FBI Atlanta's Residential Reentry Management Office. Hill is currently subject to supervised probation for the next six years and is required to complete 100 hours of community service.
