Kingsley v. Hendrickson

PETITIONER: Michael B. Kingsley
RESPONDENT: Stan Hendrickson
LOCATION: Monroe County Jail

DOCKET NO.: 14-6368
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 576 US (2015)
GRANTED: Jan 16, 2015
ARGUED: Apr 27, 2015
DECIDED: Jun 22, 2015

ADVOCATES:
John F. Bash - Assistant to the Solicitor General, Department of Justice
Paul D. Clement - for the respondents
Wendy M. Ward - for the petitioner

Facts of the case

In May 2010, Michael Kingsley, who was being held as a pretrial detainee in Monroe County Jail, was ordered to take down a piece of paper covering the light above his cell bed but refused to do so. After Sergeant Stan Hendrickson ordered Kingsley to take down the paper several times and each time was met with refusal, Lieutenant Robert Conroy, the jail administrator, ordered the jail staff to take down the paper and transfer Kingsley to another cell. During the transfer, Kingsley refused to act as ordered, so the officers pulled him to his feet in such a manner that his feet hit the bedframe, which caused pain and made him unable to walk or stand. In the new cell, when Kingsley resisted the officers' attempts to remove the handcuffs, Hendrickson put his knee in Kingsley's back and Kingsley yelled at him. Kingsley also claimed that Hendrickson smashed his head into the concrete bunk. After further verbal exchange, another officer applied a taser to Kingsley's back.

Kingsley sued Hendrickson and other jail staff members and claimed that their actions violated his due process rights under the Fourteenth Amendment. The jury found the defendants not guilty. Kingsley appealed and argued that the jury was wrongly instructed on the standards for judging excessive force and intent. The U.S. Court of Appeals for the Seventh Circuit reversed.

Question

When the plaintiff is a pretrial detainee, are the requirements of an excessive force claim satisfied by showing that the state actor deliberately used force and the use of force was objectively unreasonable?

Media for Kingsley v. Hendrickson

Audio Transcription for Oral Argument - April 27, 2015 in Kingsley v. Hendrickson

Audio Transcription for Opinion Announcement - June 22, 2015 in Kingsley v. Hendrickson

Justice Breyer has our opinion this morning in Case 14-6368, Kingsley v. Hendrickson.

Stephen G. Breyer:

Michael Kingsley was arrested on a drug charge.

He was held in a state jail pending his trial.

And while he was held there, he and jail officers engaged in an altercation and that ended up with Kingsley suing the jailers in Federal Court for using “excessive force” in violation of the Fourteenth Amendment.

The jury found in favor of the jail officers.

Kingsley said that the judge had used the wrong jury instruction, an instruction that was too favorable to the officers.

The Seventh Circuit Court of Appeals disagreed with Kingsley and felt the instruction was okay, and now we must decide what the proper standard is for determining when officers have used excessive force against a pretrial detainee, i.e., a prisoner who has not yet been convicted of a crime.

In particular, must the detainee show that the officers when using force had an improper subjective state of mind or need the prisoner who is complaining about the officer show only that the officer's use of force was objectively unreasonable?

We hold that the objective standard is the correct standard.

Now, at the outset we distinguish between due to different state of mind questions that could come up in a case like this one.

The first question concerns the officer's state of mind with respect to the physical things that go on in the world.

Did that officer intend to bring about the physical consequences that came about, say a swing of his fist that hits the prisoner's face, say a push that leads to a fall, or a shot with a taser that stuns a detainee?

Now, here it's conceded that the officers intended to cause those physical effects in the world, so we don't have to consider more about what state of mind you have to show in respect to those physical things that go on in the world, they did intend them.

But the question before us is a different question.

It concerns the legal interpretation of those physical things, that is, did those physical things involve the use of force that was excessive?

It is with respect to this question that we hold that Courts do not apply a subjective standard focusing on the state of mind of the officers, rather in respect to the question of excessiveness, was it excessive or not, they use an objective standard.

A pretrial detainee must show that the force that was purposely used or was knowingly used against the prisoner was objectively unreasonable.

The standard though objective should not be applied mechanically.

Reasonableness turns on the facts and circumstances of the particular case.

A Court in making its objectively unreasonable determination must proceed from the perspective of a reasonable officer on the scene, taking account of the legitimate interests that stem from the need to manage the jail facility, to maintain internal order, to maintain security, and so forth.

In our opinion we list further factors that may bear on the question of whether force was or was not objectively unreasonable.

We explain why we believe our conclusion is consistent with precedent and we set forth other reasons for concluding that an objective, not a subjective standard applies.

We conclude that the instruction given in this case was not consistent with the standard that we set forth.

We remand the case for a determination as to whether any deviation from that standard was harmless or harmful.

For these and other reasons set forth in our opinion, we vacate the decision of the Seventh Circuit Court of Appeals.

We remand the case for further proceedings.

Justice Scalia has written a dissenting opinion, in which he is joined by the Chief Justice and Justice Thomas.

Justice Alito has also written a dissenting opinion.

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