Managing Risk: Recommendations for Safer Restraint Chair Practices

restraint chair

Posted By: publisher November 14, 2025

John G. Peters, Jr., Ph.D., and Mitchell Lucas

©2025. A.R.R.

There has been a marked increase in criminal prosecutions and civil litigation involving the alleged misuse of restraint chairs to control or confine individuals, primarily within correctional settings.

A notable case occurred in Clayton County, Georgia, where former Sheriff Victor Hill was convicted and sentenced to 18 months in prison for improperly placing new inmates in a restraint chair as a form of punishment. Surveillance video and audio evidence showed that there was no legitimate correctional or security reason for restraining these pretrial detainees.

Civil litigation resulting in large settlements are using precious monetary resources to make these cases go away, but, often, it is back to business as usual when it comes to using restraint chairs without updating policies, training and/or accountability. A sample of these cases and settlements include:

  • $7 million to settle the death of Christian Black who died following being placed into a restraint chair in Montgomery, Ohio;
  • $12.5 million to settle a case where a male was held in a restraint chair for more than 48 hours in the Garfield County (OK) Detention Center;
  • $5 million to settle a case where an inmate was in a restraint chair more than 46 hours in San Louis Obispo County, CA;
  • $2.3 million to settle the death of Nicholas Fara, Las Vegas, NV;
  • Several million dollars to settle the death of Scott Norberg who was in a restraint chair when his head was forced into his chest while gagged and a stun gun was applied to him in the Maricopa County (AZ) Jail; and
  • $750k to settle a case in the Sacramento County (CA) Jail.

Restraint Chair Development

Although people have been restrained in some form of restraint chair-like device for centuries around the world and mostly in mental asylums in the United States, a restraint chair patent was issued in 1998 by the Patent and Trademark Office. Per the patent, it is issued for “a chair device in which a hyperactive patient or prisoner can be held and moved about while maintaining control of the person and moved without undue force.”

Restraint Chair Decision-making and Application

An individual’s erratic, violent and/or self-harming behavior usually form the basis for the decision to place such an individual into a restraint chair. Many times, the confrontation with correctional officers begins in the sally port, in a cell or in an infirmary, where officers are called to capture and control the individual. In some cases, force options to control the individual include empty hand control, including strikes, pepper spray, electronic control weapons, and/or multiple officers grounding the subject. Handcuffing generally follows the grounding of the person which is prior to placing him or her into a restraint chair. Decision-making is often based upon the detainee’s behavior, agency policy and restraint chair training.

It often takes two or three officers to place the individual – resisting or not – into a restraint chair. After (s)he is seated, wrist and ankle straps are secured, in addition to an upper body strap to hold the person comfortably against the chair’s back support. Berzlanovich, Schoper, and Keit (2012) cautioned “improper application of restraining straps can lead to injuries such as cutaneous abrasions, bruises, soft tissue compression, neural lesions, and fractures…and possibly asphyxiation.” The placement of an individual into a restraint chair is a freedom-restraining measure which directly places the care of the person on the officers and/or medical staff.

Restraint Chair Safety

Castillo, Coyne, Chan, Hall, and Vilke (2015) observed a restraint chair “is one such tool used to protect both the law enforcement officer as well as the subject.” After performing a “structured literature review” of 21 peer-reviewed studies, they identified two major categories of risks: legal and medial liability. The researchers identified very few risks which are directly associated with using a restraint chair to control humans.  

Visaggio, Phillips, Kichefski, McElhinney, Idiculla, Blair, and Young (2018) studied the use of restraint chairs in a medical setting. They noted that “in law enforcement and corrections, few risks have been directly related to the use of the restraint chair and available medical literature suggests that deaths associated with the use of the restraint chair have occurred for reasons other than the chair itself.” Noting that the ability to have a person sitting upright is good for medical assessment and intervention, it also should also reduce or eliminate claims of compressional asphyxiation.

Restraint Chair Concerns

Assorted studies on restraint chairs have identified several concerns regarding their use by law enforcement officers. Several of the concerns have been validated by separate studies so it is important to review them and make sure they have been addressed by your agency. While there are several legal and general commentary articles about using restraint chairs, there are limited scientific studies about them. A limited literature review focusing on restraint chair concerns include Blier (2025), Granwehr (2024), Phillips, et al. (2018), and Castillo, et al. (2015).   

Restraint chair agency and user concerns include, but are not limited to:

  • Failure to read the restraint chair’s manufacturer product warnings;
  • Failure to have a restraint chair policy;
  • Failure to provide clarity and clear guidance to officers within a restraint chair policy;
  • Failure to provide competency-based training on the proper use of a restraint chair;
  • Failure to limit the duration of time a person is held in a restraint chair;
  • Failure to document the use of a restraint chair (e.g., reason for use, duration, checks on restrained individual, etc.);
  • Failure to document medical checks on the restrained individual;
  • Failure to document the condition of the restraint;
  • Failure to monitor the restrained individual;
  • Failure to evaluate the mental health of an individual before being placed into a restraint chair (i.e., this should be done following intake);
  • Failure to keep frequency of restraint chair use statistics;
  • Failure to separately remove wrist and/or ankle restraints for short periods of time allowing for hand, wrist, ankle, and/or foot flexation;
  • Failure to remove a restrained person from a restraint chair for timely bathroom and physical movement breaks;
  • Failure to internally investigate the alleged misuse of a restraint chair by officer(s); and
  • Failure to discipline officer(s) for failing to follow restraint chair policy and/or training.

Risk Management Strategies: Restraint Chairs

There are several strategies which can be implemented to reduce liability exposure of the municipality, officers, administrators, and/or private corrections. The foundation for these strategies is rooted in experience, restraint chair scientific studies, legal holdings, manufacturer warnings, and/or career and technical educational standards. Use the following as a checklist to identify what your agency has in place, what it is missing and what can be upgraded, and then develop a realistic implementation strategy to minimize liability exposure. It should be noted that standard “transport safety seats” commonly installed in patrol vehicles fall outside the scope of this article and should not be categorized as restraint chairs. However, as a general guideline, when a patrol vehicle is equipped with such a seat, officers should ensure that the individual is never left unsupervised and not kept in the seat for an extended period. Prolonged restraint can pose risks related to circulation, respiration and exposure to extreme temperatures, such as excessive heat in summer or cold in winter.

The restraint chair can be a highly effective tool for keeping officers, medical staff, and inmates safe, but clear policies which address training, appropriate use and documentation of its use, are essential to all law enforcement facilities which use or are anticipating using restraint chairs. These strategies are appliable to federal, state and local agencies which use restraint chairs. A July 2025 report by the Department of Justice, Office of Inspector General, issued after an audit pertaining to the use of restraints on Bureau of Prison inmates, said this:

“Clearer and more robust policies would assist the BOP in protecting inmates from abusive treatment, shielding staff from false allegations, deterring misconduct by staff, and holding staff who engage in misconduct accountable.”

Restraint chair policy: The policy must be comprehensive and should include the following recommended provisions:

  • When the restraint chair can be used:
    • To protect a person from self-harm;
    • To control a person who is actively trying to harm others;
    • To control a person who is actively trying to damage property; and
    • To enhance and continue the agency’s culture and climate of safety.
  • Pregnant females shall not be placed into a Restraint Chair.
  • The restraint chair is never used to punish or discipline any person or for the convenience of staff. Respect the civil rights of individuals.
  • Lesser restrictive alternatives shall be considered before placing an individual into a restraint chair.
  • A supervisor must authorize any use of a restraint chair. In exigent circumstances, supervisor approval must be obtained immediately following the placement of a person into a restraint chair.
  • Only staff who have successfully completed an agency approved, competency-based training program (i.e., IPICD Restraint Chair Instructor or User-Level qualification program) are authorized to secure an individual into a restraint chair.
  • On-the-job restraint chair training must follow the restraint chair lesson guide and competency-based assessment criteria.
  • Medical and/or psychological professionals must be consulted (unless exigent circumstances prohibit such consultation) before any person with known medical conditions, such as prosthetics or other medical hardware attached to the body, or physical deformities, is placed into a restraint chair.
  • As circumstances permit, after a person is placed into a restraint chair, a medical professional should examine him or her to ensure there is adequate circulation, respiration and the person is otherwise medically fit (vital signs) to be placed in the restraint chair.
  • Pepper spray, electronic control weapons and/or impact tools shall not be used on any person who is restrained in a restraint chair.
  • Spit restraint devices shall only be applied after approval of a supervisor.
  • Employees should wear Personal Protective Equipment (PPE) when placing and securing an individual into a restraint chair.
  • When video and/or audio recording devices are available, the placement of an individual into a restraint chair shall be recorded, either by handheld camera, body-worn camera and/or surveillance cameras.
  • The individual must be directly monitored by a staff member for the duration of placement in the restraint chair. (Remote video monitoring is not sufficient because blood circulation, respiration and mental status must be observed and checked.)
  • At no time shall an individual restrained in a restraint chair be placed out of view from officers and/or medical staff (e.g., solitary confinement).
  • Staff must unfasten and exercise individual limbs, one at a time, in timely intervals, not to exceed 30 minutes. After all the limbs have been exercised and replaced into the restraints, a medical professional should again check the inmate for adequate blood circulation.
  • As necessary or appropriate, permit the individual to use the bathroom, eat and drink water.
  • Treat claims of “I can’t breathe,” or “I’m having trouble breathing,” or “my arms and/or legs are getting numb” as medical emergencies and immediately contact medical professionals to evaluate the person.
  • There must be a specific maximum length of confinement in the restraint chair, typically not longer than two hours.
  • Documentation must include a complete use-of-force report which provides:
    • The reason for placing the individual into a restraint chair.
    • The name and rank of the supervisor who authorized the use.
    • The names of all staff involved.
    • The names of all medical personnel involved.
    • The time the inmate was placed in, and the time the inmate was removed from, the restraint chair.
    • The dates and times the limbs were exercised.
  • The appropriate members of the command staff shall review the documentation and videos.
  • Only those employees who have successfully completed and have demonstrated competence in restraint chair use are permitted to secure an individual in a restraint chair.
  • Employees shall be held accountable for knowing the restraint chair policy, maintaining competency in the uses of a restraint chair and for reporting alleged use abuses.
  • Annually, the restraint chair policy shall be reviewed and approved by the legal counsel, including and updated accordingly.

Summary

Deaths and serious injuries associated with restraint chairs will most likely continue and result in civil lawsuits and, in some cases, criminal prosecutions. This is particularly true in states which have passed legislative mandates about the placement of individuals in a position where they can asphyxiate. Police and correctional officers encounter many people who are fragile from chronic or acute drug use, mental health, or medical issues, and/or violently resist them. Some of these individuals may be disabled per the Americans With Disabilities Act which may cause separate litigation issues, beyond the scope of this article. Fostering a culture and climate of safety within the organization is important and can help shield your agency from potential criminal prosecution and civil liability.

John G. Peters, Jr., Ph.D. serves as president of the Henderson, Nevada-based Institute for the Prevention of In-Custody Deaths, Inc. (IPICD). He is the curator and co-developer of two new Institute programs, “Situational M.O.N.I.T.O.R™ Specialist” which educates, trains and qualifies officers on how to monitor and identify situations for asphyxia, abnormal breathing and other life-threatening issues, and “Restraint Chair Instructor.” He is a judicially qualified expert witness who has testified in international, federal and state courts, and is a graduate of the MIT Sloan School of Management and the Computer Science Artificial Intelligence Laboratory (CSAIL) on Artificial Intelligence and the University of Nevada, Las Vegas, on Artificial Intelligence Automation.

Mitchell Lucas serves as an expert witness and is a retired assistant sheriff of a South Carolina Sheriff’s Office. “Mitch” is a past president of the American Jail Association and has taught classes on jail topics around the country, as well as making presentations on correctional issues for the National Institute of Corrections, at the annual conferences of the American Jail Association, the American Correctional Association, and the Americans for Effective Law Enforcement, Inc. jail seminar. Prior to being promoted to Assistant Sheriff, he was the Chief Deputy/Jail Administrator at the Sheriff’s Office.