Supreme Court Decides Kingsley v. Hendrickson
On June 22, 2015, the U.S. Supreme Court decided Kinsgley v. Hendrickson, No. 13-1175, holding that to prove an excessive force claim, a pretrial detainee need show only that an officer’s deliberate use of force was objectively unreasonable.
Michael Kingsley was detained in a Wisconsin county jail before trial. Based on factual allegations disputed by the officers, Kingsley brought suit under 42 U.S.C. § 1983, claiming that the officers used excessive force against him in violation of the Fourteenth Amendment’s Due Process Clause. At trial, the District Court instructed the jury that “excessive force” is “force applied recklessly that is unreasonable in light of the facts and circumstances of the time.” The jury found in the officers’ favor and Kingsley appealed. The Seventh Circuit affirmed, concluding that the law required a “subjective inquiry” into the officer’s state of mind and that there must be “an actual intent to violate [the plaintiff’s] rights or reckless disregard for his rights.”
The Supreme Court vacated the Seventh Circuit’s decision, holding that to succeed on an excessive force claim under § 1983, a plaintiff need only show that the officer’s deliberate use of force was objectively unreasonable. Although the officer’s use of force itself must be deliberate — as opposed to accidental or negligent — a plaintiff is not required to make a subjective inquiry into the officer’s state of mind. The Court went on to note that courts cannot “apply this standard mechanically,” and that objective reasonableness turns on the “facts and circumstances of each particular case” based on the perspective of a reasonable officer at the scene. The court should also account for the “legitimate interests” of managing a detention facility and should consider factors such as the relationship between the need for the use of force, the amount of force used, and the extent of the plaintiff’s injury. The Court rejected any notion that use of an objective standard would lead to a “rash of unfounded filings” in district courts.
Based on this analysis, the Court concluded that the jury instruction given in Kingsley’s case was erroneous. The instruction improperly suggested that the jury “should weigh the officers’ subjective reasons for using force” and “subjective views about the excessiveness of the force.” The Court remanded to the Court of Appeals to consider whether the error was harmless in light of the specific facts of the case.
Justice Breyer delivered the opinion of the Court, in which Justices Kennedy, Ginsburg, Sotomayor, and Kagan joined. Justice Scalia filed a dissenting opinion joined by Chief Justice Roberts and Justice Thomas. Justice Alito also filed a dissenting opinion.
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