Wilkins v. Gaddy

E914625

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.

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Label Occurrences
Wilkins v. Gaddy canonical 1

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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 ⓘ
constitutionalProvision Eighth Amendment to the United States Constitution ⓘ
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. ⓘ
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 ⓘ
legalIssue Eighth Amendment excessive force standard ⓘ
requirement of more-than-de-minimis injury ⓘ
locationOfOrigin North Carolina ⓘ
lowerCourt United States Court of Appeals for the Fourth Circuit ⓘ
United States District Court for the Western District of North Carolina ⓘ
opinionBy Justice Ruth Bader Ginsburg ⓘ
linked to: Ruth Bader Ginsburg
opinionType per curiam opinion ⓘ
overrules Fourth Circuit more-than-de-minimis injury requirement for excessive force claims ⓘ
petitioner Jamey Lamont Wilkins ⓘ
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 ⓘ
remedy Case remanded for further proceedings consistent with the Supreme Court’s opinion. ⓘ
respondent Officer Gaddy ⓘ
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) ⓘ
linked to: Hudson v. McMillian
subjectMatter prison conditions ⓘ
use of force by correctional officers ⓘ
term October Term 2009 ⓘ
vote unanimous ⓘ

How these facts were elicited

Referenced by (1)

Full triples — surface form annotated when it differs from this entity's canonical label.

Hudson v. McMillian → relatedCase → Wilkins v. Gaddy ⓘ