Bulls v. Conely (INMATE 3)

On August 16, 2024, at Donaldson Correctional Facility in Alabama, inmate Michael Conely (identified as Inmate #3) allegedly struck Correctional Officer John Bulls multiple times during a cell extraction, causing a fractured orbital bone and lacerations. Officer Bulls filed a civil tort lawsuit in federal court seeking damages for assault and battery. Conely contended that Bulls initiated excessive force without provocation and that his actions were purely self-defense. The case turned on conflicting surveillance footage and testimony from other inmates and staff. The jury had to weigh whether Conely’s response was proportionate under the circumstances of an inherently coercive prison environment.

The jury returned a split verdict, finding Conely liable for battery but determining Bulls was 40% comparatively negligent. Conely was ordered to pay reduced compensatory damages of $22,000, with no punitive damages awarded.

The central issue was whether inmate Conely’s use of force constituted unlawful assault and battery, or whether it was a legally justified act of self-defense against the correctional officer’s alleged excessive use of force.

The case drew attention from prison reform advocates and correctional officer unions, highlighting the thin line between institutional discipline and inmate mistreatment. It spurred calls for mandatory body cameras on prison staff and independent oversight of use-of-force incidents within state penitentiaries.