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Prison worker’s training injury comp claim, not constitutional seizure - Business Insurance Skip to content Register for free Search Search Log In Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Risk Management Cyber Risks Pricing Trends Mergers & Acquisitions Technology Sponsored Content WSIA RISKWORLD Workers Comp & Safety Workers Comp Cost Control Pain Management Workplace Safety International EMEA Asia-Pacific Latin America People Events BI Intelligence Top 100 Agents & Brokers Best Places to Work 2025 Lists Directories Insurance Pricing BI Stock Index Magazine Current Issue Past Issues Subscribe Women to Watch ALL INsurance Resources Risk Perspectives Sponsored Content Webinars White Papers Prison worker’s training injury comp claim, not constitutional seizure by Louise Esola Claims Disputes , Workers Comp Coverage , Workplace Safety Aug 12, 2026 A federal appeals court ruled Tuesday that a Michigan prison employee injured during a hostage-training exercise was not “seized” under the Fourth Amendment and could not proceed with an excessive-force claim against two corrections officers. In Arthur v. Krause , the 6th U.S. Circuit Court of Appeals affirmed summary judgment against Danielle Arthur, a mental-health professional formerly employed at the Oaks Correctional Facility. Ms. Arthur agreed to act as a hostage during an April 2023 training exercise. The assistant deputy warden played the hostage taker, and a team of officers was directed to enter an office and subdue him. During the exercise, one officer struck another with a shield as another officer grabbed his knee. The maneuver pushed the officer into Ms. Arthur, pinning her against an armchair as several team members fell partially on top of them. An MRI later showed that Ms. Arthur suffered a low-grade posterior cruciate ligament sprain, bone contusions and an incomplete impaction fracture. Ms. Arthur sued the participating officers, but her sole remaining claim alleged that two of them used excessive force in violation of the Fourth Amendment. The 6th Circuit said a Fourth Amendment seizure requires force applied with an intent to restrain or a show of authority that results in actual control. The officers’ objective was to practice responding to a hostage situation, not to exercise actual law enforcement authority or restrain Ms. Arthur, the court said. Her accidental injury therefore did not constitute a seizure. Ms. Arthur had also voluntarily participated in the exercise, and the exercise ended immediately after she cried out in pain, undermining her argument that the officers had acquired control over her, the court said. The court noted that its ruling does not prevent government employees injured during workplace training from seeking other remedies. Ms. Arthur acknowledged during oral arguments that she had successfully pursued a workers compensation claim. The court also held that any error by the trial judge in failing to decide Ms. Arthur’s motion for evidentiary sanctions before granting summary judgment was harmless because the requested sanctions would not change the constitutional analysis. 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