×
You have 2 more free articles available this month. Subscribe today.
U.S. Supreme Court Holds Significant Injury Unnecessary for Excessive Force Claims
More than de minimis injury is not required to state an excessive force claim, the U.S. Supreme Court unanimously decided on February 22, 2010.
In Hudson v. McMillian, 503 U.S. 1 (1992) [PLN, May 1992, p.3], the Supreme Court recognized that “the use of excessive physical force against a prisoner may constitute cruel and unusual punishment [even] when the inmate does not suffer serious injury.”
In spite of this holding, since Hudson was decided several lower courts have required prisoners to allege more than “de minimis” injury in order to state an excessive force claim.
Such was the case with Jamey L. Wilkins, a North Carolina state prisoner who sued a guard for “maliciously and sadistically” assaulting him “[w]ithout any provocation.”
According to Wilkins’ complaint, the guard, identified only as “Officer Gaddy,” became incensed after Wilkins asked for a grievance form. Gaddy allegedly “snatched [Wilkins] off the ground and slammed him onto the concrete floor,” and “then proceeded to punch, kick, knee and choke [Wilkins] until another [guard] had to physically remove him from [Wilkins].” Wilkins claimed he suffered numerous injuries, including “a bruised heel, lower back pain, increased blood pressure, as well as migraine headaches and dizziness” as a result of the attack.
Wilkins’ allegations, however, were not sufficient enough for the district court. Relying on existing Fourth Circuit precedent, the district court, on its own motion, dismissed Wilkins’ complaint, holding that he had failed to state an excessive force claim because his injuries were not more than de minimis.
Following summary affirmance by the Fourth Circuit Court of Appeals, the Supreme Court granted certiorari and vacated the lower court’s judgment in a per curiam opinion.
“In requiring what amounts to a showing of significant injury,” the Supreme Court wrote, “the Fourth Circuit ha[d] strayed from the clear holding of [the] Court in Hudson.”
Hudson, the Supreme Court explained, sought to “shift the core judicial inquiry from the extent of the injury to the nature of the force – specifically, whether it was nontrivial and was applied ... maliciously and sadistically to cause harm.” This shift was necessary because “[o]ther- wise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury.”
By concluding that the “absence of ‘some arbitrary quantity of injury’ requires automatic dismissal of an excessive force claim,” the district court and the Fourth Circuit had bypassed this core inquiry. “An inmate who is gratuitously beaten by guards does not lose his ability to pursue an excessive force claim merely because he has the good fortune to escape without serious injury,” the Supreme Court explained.
The judgment of the lower court was accordingly reversed and the case remanded for further proceedings. See: Wilkins v. Gaddy, 130 S.Ct. 1175 (2010).
In Hudson v. McMillian, 503 U.S. 1 (1992) [PLN, May 1992, p.3], the Supreme Court recognized that “the use of excessive physical force against a prisoner may constitute cruel and unusual punishment [even] when the inmate does not suffer serious injury.”
In spite of this holding, since Hudson was decided several lower courts have required prisoners to allege more than “de minimis” injury in order to state an excessive force claim.
Such was the case with Jamey L. Wilkins, a North Carolina state prisoner who sued a guard for “maliciously and sadistically” assaulting him “[w]ithout any provocation.”
According to Wilkins’ complaint, the guard, identified only as “Officer Gaddy,” became incensed after Wilkins asked for a grievance form. Gaddy allegedly “snatched [Wilkins] off the ground and slammed him onto the concrete floor,” and “then proceeded to punch, kick, knee and choke [Wilkins] until another [guard] had to physically remove him from [Wilkins].” Wilkins claimed he suffered numerous injuries, including “a bruised heel, lower back pain, increased blood pressure, as well as migraine headaches and dizziness” as a result of the attack.
Wilkins’ allegations, however, were not sufficient enough for the district court. Relying on existing Fourth Circuit precedent, the district court, on its own motion, dismissed Wilkins’ complaint, holding that he had failed to state an excessive force claim because his injuries were not more than de minimis.
Following summary affirmance by the Fourth Circuit Court of Appeals, the Supreme Court granted certiorari and vacated the lower court’s judgment in a per curiam opinion.
“In requiring what amounts to a showing of significant injury,” the Supreme Court wrote, “the Fourth Circuit ha[d] strayed from the clear holding of [the] Court in Hudson.”
Hudson, the Supreme Court explained, sought to “shift the core judicial inquiry from the extent of the injury to the nature of the force – specifically, whether it was nontrivial and was applied ... maliciously and sadistically to cause harm.” This shift was necessary because “[o]ther- wise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury.”
By concluding that the “absence of ‘some arbitrary quantity of injury’ requires automatic dismissal of an excessive force claim,” the district court and the Fourth Circuit had bypassed this core inquiry. “An inmate who is gratuitously beaten by guards does not lose his ability to pursue an excessive force claim merely because he has the good fortune to escape without serious injury,” the Supreme Court explained.
The judgment of the lower court was accordingly reversed and the case remanded for further proceedings. See: Wilkins v. Gaddy, 130 S.Ct. 1175 (2010).
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
Related legal case
Wilkins v. Gaddy
| Year | 2010 |
|---|---|
| Cite | 130 S.Ct. 1175 (2010) |
| Level | Supreme Court |
| Injunction Status | N/A |