Wilkins v. Gaddy
E914625
Eighth Amendment case
United States Supreme Court case
excessive force case
prisoner civil rights case
Wilkins v. Gaddy is a 2010 U.S. Supreme Court decision clarifying that the core inquiry in Eighth Amendment excessive force claims is the nature of the force used rather than the extent of the inmate’s injury.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Wilkins v. Gaddy canonical | 1 |
Statements (43)
| Predicate | Object |
|---|---|
| instanceOf |
Eighth Amendment case
ⓘ
United States Supreme Court case ⓘ excessive force case ⓘ prisoner civil rights case ⓘ |
| causeOfAction | 42 U.S.C. § 1983 ⓘ |
| citation |
130 S. Ct. 1175
ⓘ
175 L. Ed. 2d 995 ⓘ 559 U.S. 34 ⓘ |
| clarifies | Hudson v. McMillian NERFINISHED ⓘ |
| constitutionalProvision | Eighth Amendment to the United States Constitution NERFINISHED ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 2010-02-22 ⓘ |
| docketNumber | 08-10914 ⓘ |
| factSummary | A North Carolina state prisoner alleged that a corrections officer assaulted him without provocation, slamming him to the ground and punching, kicking, and choking him. ⓘ |
| holding |
A significant injury is not a threshold requirement for an Eighth Amendment excessive force claim.
ⓘ
The Fourth Circuit erred by requiring a showing of more-than-de-minimis injury to proceed with an excessive force claim. NERFINISHED ⓘ The absence of serious injury is relevant but not dispositive in an Eighth Amendment excessive force analysis. ⓘ The core judicial inquiry in an Eighth Amendment excessive force claim is the nature of the force used, not the extent of the injury suffered. ⓘ |
| impact |
Lower courts may not impose a categorical significant-injury threshold for Eighth Amendment excessive force claims.
ⓘ
Reinforced that minor injuries can still support an Eighth Amendment excessive force claim if the force was malicious and sadistic. ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| legalIssue |
Eighth Amendment excessive force standard
ⓘ
requirement of more-than-de-minimis injury ⓘ |
| locationOfOrigin | North Carolina NERFINISHED ⓘ |
| lowerCourt |
United States Court of Appeals for the Fourth Circuit
NERFINISHED
ⓘ
United States District Court for the Western District of North Carolina NERFINISHED ⓘ |
| opinionBy | Justice Ruth Bader Ginsburg NERFINISHED ⓘ |
| opinionType | per curiam opinion ⓘ |
| overrules | Fourth Circuit more-than-de-minimis injury requirement for excessive force claims ⓘ |
| petitioner | Jamey Lamont Wilkins NERFINISHED ⓘ |
| principle |
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.
ⓘ
Injury and force are imperfectly correlated in excessive force cases. ⓘ |
| proceduralHistory |
The Supreme Court granted certiorari and reversed the judgment of the Fourth Circuit.
ⓘ
The district court dismissed the complaint for failure to allege more-than-de-minimis injury, and the Fourth Circuit affirmed. ⓘ |
| relatedCase | Hudson v. McMillian NERFINISHED ⓘ |
| remedy | Case remanded for further proceedings consistent with the Supreme Court’s opinion. ⓘ |
| respondent | Officer Gaddy NERFINISHED ⓘ |
| standard | Excessive force claims turn on whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm. ⓘ |
| standardSource | Hudson v. McMillian, 503 U.S. 1 (1992) NERFINISHED ⓘ |
| subjectMatter |
prison conditions
ⓘ
use of force by correctional officers ⓘ |
| term | October Term 2009 ⓘ |
| vote | unanimous ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.