Kingsley v. Hendrickson
192 L. Ed. 2d 416, 2015 U.S. LEXIS 4073, 135 S. Ct. 2466 (2015)
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Rule of Law:
To establish an excessive force claim under the Fourteenth Amendment's Due Process Clause, a pretrial detainee must show that the force purposely or knowingly used against them was objectively unreasonable. The detainee is not required to prove the officer's subjective state of mind, such as malicious or sadistic intent to cause harm.
Facts:
- Michael Kingsley, a pretrial detainee in a Wisconsin county jail, repeatedly refused orders from officers to remove a piece of paper covering a light fixture in his cell.
- After Kingsley's continued refusal, jail administrator Lieutenant Robert Conroy ordered officers to remove the paper and move Kingsley to a receiving cell.
- Four officers, including Sergeant Stan Hendrickson and Deputy Sheriff Fritz Degner, entered Kingsley's cell to carry out the order.
- When Kingsley refused to comply with their commands, the officers handcuffed him, forcibly removed him from the cell, and placed him face-down on a bunk in the receiving cell.
- While the officers were attempting to remove his handcuffs, Hendrickson placed his knee on Kingsley's back.
- Following a verbal exchange, Hendrickson directed Degner to use a Taser on Kingsley.
- Degner applied the Taser to Kingsley's back for approximately five seconds.
Procedural Posture:
- Michael Kingsley filed a lawsuit against Sergeant Hendrickson and Deputy Degner in the U.S. District Court for the Western District of Wisconsin, alleging excessive force.
- The district court denied the officers' motion for summary judgment, and the case proceeded to a jury trial.
- The jury was instructed that to succeed, Kingsley must prove the officers applied force 'recklessly' and with 'reckless disregard' for his safety.
- The jury returned a verdict in favor of the defendant officers.
- Kingsley, as appellant, appealed the verdict to the U.S. Court of Appeals for the Seventh Circuit.
- A divided panel of the Seventh Circuit, with the officers as appellees, affirmed the district court's judgment, holding that an excessive force claim required a subjective inquiry into the officer's state of mind.
- The U.S. Supreme Court granted Kingsley's petition for a writ of certiorari to resolve a circuit split on the issue.
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Issue:
Does a pretrial detainee bringing an excessive force claim under the Fourteenth Amendment's Due Process Clause have to prove that the officers acted with a subjectively culpable state of mind, or only that the force used was objectively unreasonable?
Opinions:
Majority - Justice Breyer
No. To prove an excessive force claim, a pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable; a showing of the officer's subjective state of mind is not required. The Due Process Clause protects pretrial detainees from force that amounts to punishment. Citing Bell v. Wolfish, the court explained that in the absence of an expressed intent to punish, a detainee can prevail by showing that the actions were not 'rationally related to a legitimate nonpunitive governmental purpose' or were 'excessive in relation to that purpose,' which is an objective inquiry. This objective standard is workable, consistent with the Fourth Amendment standard for arrestees, and adequately protects officers who act in good faith, especially when combined with qualified immunity. The 'maliciously and sadistically' standard from Eighth Amendment cases involving convicted prisoners is inapplicable because pretrial detainees cannot be subjected to any form of punishment.
Dissenting - Justice Scalia
Yes. A pretrial detainee's due process claim requires a showing that the officer acted with a subjective intent to punish. The Due Process Clause only prohibits 'punishment' of pretrial detainees, which under Bell v. Wolfish, requires a 'purpose of punishment.' While objective factors can be used as circumstantial evidence to infer punitive intent for considered, facility-wide policies, it is illogical to automatically infer punitive intent from a guard's split-second decision to use force. An officer's misjudgment about the necessary degree of force does not automatically equate to a subjective intent to punish. Adopting an objective reasonableness standard improperly transforms the Fourteenth Amendment into a 'font of tort law,' superimposing it over existing state law remedies.
Dissenting - Justice Alito
This dissent does not directly answer the issue but argues the case should be dismissed as improvidently granted. Before deciding the Fourteenth Amendment substantive due process question, the Court should first determine if a pretrial detainee can bring an excessive force claim under the Fourth Amendment. If a Fourth Amendment claim, with its established objective reasonableness standard, is available to pretrial detainees, there would be no need or justification to rely on the more nebulous doctrine of substantive due process to analyze the claim, in accordance with the Court's precedent in Graham v. Connor.
Analysis:
This decision resolves a circuit split by establishing a uniform, objective standard for pretrial detainee excessive force claims, making the legal test more plaintiff-friendly. It aligns the rights of pretrial detainees more closely with those of free citizens under the Fourth Amendment, while maintaining a clear distinction from the subjective 'malice' standard applied to convicted prisoners' Eighth Amendment claims. By removing the need to prove an officer's subjective state of mind, the ruling makes it easier for such claims to survive summary judgment and proceed to a jury, potentially increasing the liability of correctional facilities and their officers.
