Wilkins v. Gaddy

Jamey Wilkins (hereinafter “the Plaintiff”) filed an excessive force suit against Gaddy (hereinafter “the Defendant”) under 42 U.S.C. § 1983 in violation of the Eighth Amendment of the United States Constitution.  The Plaintiff was a state prisoner in North Carolina when he had asked a correctional officer, the Defendant, for a grievance form, and the Defendant had reacted angrily to this request by slamming the Plaintiff to the ground. He continued by punching, kicking, and choking the Plaintiff; the Defendant had to be restrained by another guard.

Wilkins alleged that as a result of the attack he sustained a bruised heel, lower back pain, increased blood pressure, migraine headaches, dizziness, and psychological trauma resulting in panic attacks and nightmares.

The district court dismissed the complaint for failure to state a claim. Citing Circuit precedent, they held that an excessive force claim under the Eighth Amendment required more than a de minimis injury. The district court’s motion for dismissal was supported by the Plaintiff’s failure to obtain medical care. During the appeals process, where the Plaintiff provided evidence that he obtained medical care, the Fourth Circuit upheld the dismissal because the evidence showed it was a de minimis injury.

Relevant Legal Provisions:

Eighth Amendment, US Constitution: “Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.”

42 U.S.C. § 1983: “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.”

The Supreme Court reversed the lower court’s decision and remanded it for further proceedings. The court reasoned that a significant injury was not necessary to file suit under the Eighth Amendment. It was necessary to show significant injury when a correctional officer was attempting to maintain order in good faith, but when force is used maliciously and sadistically to cause harm, it does not require significant injury.
However, a minor push or shove that caused no injury, even if malicious or sadistic, would not violate the Eighth amendment. The court further explained that absence of a serious injury was not unimportant to an Eighth Amendment inquiry, the injury could help explain whether the force was necessary and how much force was applied.

"This Court rejected the notion that "significant injury" is a threshold requirement for stating an excessive force claim. The "core judicial inquiry," we held, was not whether a certain quantum of injury was sustained, but rather "whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm." (Para 7)

"When prison officials maliciously and sadistically use force to cause harm," the Court recognized, "contemporary standards of decency always are violated . . . whether or not significant injury is evident. Otherwise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury."" (Para 7)

“This is not to say that the “absence of serious injury” is irrelevant to the Eight Amendment inquiry. “[T]he extent of the injury suffered by an inmate is one factor that may suggest ‘whether the use of force could plausibly have been thought necessary’ in a particular situation.” (Para 8)