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Razor wire surrounds the unused North Wing of the Wyoming State Penitentiary.

A Wyoming State Penitentiary inmate alleges a corrections officer violated his Eighth Amendment right against cruel and unusual punishment by slamming his head into a concrete floor while he was restrained, according to a lawsuit he filed in U.S. District Court. The incident, he says, was caught on camera.

“We are committed to achieving justice for our client in this case,” Doug Bailey, a Cheyenne attorney representing the prisoner, told the Star-Tribune on Friday. “Footage doesn’t lie, and we believe that after viewing the footage in this case, a jury will see that our client’s constitutional rights were violated.”

Lawyers for the guard deny the man’s account.

Jeremy Lambson was inside his cell at the maximum-security prison in Rawlins when he got into an argument with an officer on Feb. 5, 2021, the legal complaint filed in U.S. District Court states. The argument led to Lambson smashing his flat-screen TV against his cell door.

Several officers gathered at his cell because of the commotion.

A corrections officer allegedly gave an order to spray Lambson with a chemical agent through the cell’s cuff port, which is a hole used to access the hands of inmates while they are still inside their cell. Either pepper spray or tear gas was used.

Lambson started coughing and tearing up immediately and turned on a fan, the complaint states. He pointed the fan towards the bottom of his cell door in the hopes of dispersing some of the spray from his room.

Officers gave him a few minutes to catch his breath before asking him to come to the cuff port to have his hands restrained, the complaint states. He complied.

Crime in Wyoming has risen in recent years. See the details here.

Jacob Heibeck, a corrections officer at the facility, then told Lambson to kneel and face the wall. He did as he was told. Heibeck and other officers entered the cell and applied leg chains.

Heibeck and another officer stood on either side of Lambson and walked him out of his cell towards a flight of stairs, the complaint states. “He showed no resistance.”

Lambson was carried down the stairs without resisting, he maintains.

The complaint alleges that surveillance footage shows Heibeck using his full body weight to slam Lambson head-first into the ground.

“[A]nd with no provocation or justification, Defendant Heibeck slammed Lambson into the concrete floor, head first,” the complaint states. “Defendant Heibeck put all of his weight into this slam while Lambson was in a completely vulnerable position.”

The impact caused Lambson’s feet to fly upward and knocked him unconscious momentarily, which, the lawsuit says, angered other inmates who witnessed Heibeck’s “unprovoked actions.”

Heibeck is accused of holding Lambson down and refusing to allow him back up for a prolonged period of time while the prisoner pleaded for him to get off as he couldn’t breathe. Other officers eventually put a bag on his head, cuffed him to a chair and locked him in a cage for hours without treating his head injury.

The next day, a doctor at the facility diagnosed Lambson with a “closed head injury after trauma with mild concussion.” Lambson developed neck pain that got progressively worse, and he says he’s had headaches, dizziness, sensitivity to light and noise and memory issues ever since.

Heibeck inflicted unnecessary pain on him “maliciously and sadistically” rather than in a “good faith effort to maintain or restore discipline,” the lawsuit alleges.

In his legal response, Heibeck admits he took Lambson to the ground while the prisoner’s ability to move was restricted. He also agrees that Lambson’s feet momentarily moved upwards.

But Heibeck argues that Lambson was showing resistance as they moved down the stairs, and although the correctional officer took him to the ground, he didn’t use his full weight or slam his head into the ground. He denies that Lambson was knocked unconscious.

Heibeck is being represented by the Wyoming Attorney General’s Office. His attorneys did not respond to requests for comment.

Lambson was sentenced to five to six years for strangulation of a household member, and his maximum release date is in December 2024, said Paul Martin, a spokesperson for the Wyoming Department of Corrections.

Martin was unable to comment on the case due to it being active litigation but provided some insight into inmate-staff lawsuits.

Litigation in the corrections industry is a very common occurrence, so it is not a driver, in and of itself, for managing contact within the prison, said Martin.

This essentially means that Heibeck and Lambson may still have regular contact within the facility. They are not automatically kept apart because of the lawsuit.

“The primary concern in a prison is to ensure management of risks to the security of the public, the population, staff and the facility,” Martin said. “If, because of litigation an inmate feels unsafe and that offender communicates that to staff, then we will actively manage that risk and investigate on a case-by-case basis.”

If a department employee is sued by an inmate, it typically does not trigger any sort of safety or security risk management or an investigation, according to Martin.

“There is a much more expedient way an offender can make allegations of staff misconduct, which would be much more likely to invoke an investigation,” Martin said. “Offenders have the ability to make allegations of staff misconduct through the Inmate Communications and Grievance Procedure.”

Follow Sofia Saric on Twitter @Sofia_Saric.

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Razor wire surrounds the unused North Wing of the Wyoming State Penitentiary.

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