Hudson v. McMillian

PETITIONER: Hudson
RESPONDENT: McMillian
LOCATION: Angola Louisiana State Penitentiary

DOCKET NO.: 90-6531
DECIDED BY: Rehnquist Court (1991-1993)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 503 US 1 (1992)
ARGUED: Nov 13, 1991
DECIDED: Feb 25, 1992

ADVOCATES:
Alvin J. Bronstein - Argued the case for the petitioner
Harry McCall, Jr. - Argued the case for respondents

Facts of the case

Keith Hudson, a Louisiana inmate, claimed that he was beaten by Marvin Woods and Jack McMillian, two prison guards, while their supervisor, Arthur Mezo, watched. Hudson sued the guards in Federal District Court under 42 U.S.C. 1983, which allows individuals to bring suit for the "deprivation of any rights, privileges, or immunities secured by the Constitution." Hudson argued that they had violated his Eighth Amendment right to be free from cruel and unusual punishment. The District Court ruled that the guards had used force when there was no need to do so, violating the Eighth Amendment, and that Hudson was therefore entitled to damages. The Fifth Circuit Court of Appeals reversed, however, finding that an inmate must demonstrate "significant injury" when he claims that his Eighth Amendment rights have been violated by the use of excessive force.

Question

Must an inmate alleging that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by the excessive use of force demonstrate "significant injury" to prevail on his claim?

Media for Hudson v. McMillian

Audio Transcription for Oral Argument - November 13, 1991 in Hudson v. McMillian

Audio Transcription for Opinion Announcement - February 25, 1992 in Hudson v. McMillian

William H. Rehnquist:

The opinion of the Court in No. 90-6531, Hudson against McMillian will be announced by Justice O'Connor.

Sandra Day O'Connor:

This case comes to us on certiorari to the United States Court of Appeals for the Fifth Circuit.

The petitioner, Keith Hudson, was an inmate at the state penitentiary in Angola, Louisiana.

Respondents, Jack McMillian and Marvin Woods, were corrections officers at that facility.

In 1983, McMillian and Woods handcuff and shackled Hudson and led him from his cell.

According to Hudson, one of the officers then punched him in the mouth, the chest, and stomach while the other held him in place and kicked him from behind.

Hudson said that, a third respondent, the supervisor on duty at the time watched the beating and did not attempt to stop it.

Hudson suffered bruises, swelling of his face and mouth, loosened teeth and a cracked dental plate.

A magistrate determined that McMillian and Woods used force when there was no need to do so and that the supervisor condoned their actions, all in violation of Hudson's Eighth Amendment right to be free from cruel and unusual punishment.

The Court of Appeals reversed.

It held that inmates alleging use of excessive force in violation of the Eighth Amendment cannot prevail unless they prove significant injury.

Applying this rule, the Court of Appeals dismissed Hudson's action for damages on the ground that his injuries were minor.

In the opinion filed today, we reverse.

We hold that all Eighth Amendment claims alleging excessive use of force should be evaluated under the standard we have previously applied to excessive force claims arising out of efforts to put down prison disturbances.

The guiding inquiry is whether force was applied in a good faith effort to maintain or restore discipline or maliciously and sadistically for the purpose of causing harm.

The extent of the injury suffered is one factor that is relevant in determining whether the force was applied in a good faith effort to maintain discipline.

Although the Eighth Amendment's prohibition of cruel and unusual punishment excludes de minimis uses of physical force, we hold that the extent of petitioner's injuries in this case provides no basis for dismissal of his Section 1983 claim.

Justice Blackmun has filed an opinion concurring in the judgment; Justice Stevens has filed an opinion concurring in part and concurring in the judgment; Justice Thomas has filed a dissenting opinion which Justice Scalia has joined.