MEMORANDUM OPINION
DAVIS, District Judge.
This is a case of profound irony. Ostensibly to "protect" Christopher Simms, a 28-year-old pre-trial detainee known to have suffered a behavior-altering brain injury years earlier, from injuring himself, a team of three correctional officers entered Simms's cell at the Prince George's County, Maryland, Detention Center in September 1998. At the time of the officers' entry into the cell, Simms was lying on his back...
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