Wilkins v. Gaddy

PETITIONER: Jamey Wilkins
RESPONDENT: Officer Gaddy
LOCATION: Lanesboro Correctional Institution

DOCKET NO.: 08-10914
DECIDED BY: Roberts Court (2009-2010)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 559 US 34 (2010)
GRANTED: Feb 22, 2010
DECIDED: Feb 22, 2010

Facts of the case

In 2008, Jamey Wilkins, a North Carolina state prisoner, filed suit in a North Carolina federal district court. Without the aid of an attorney, he alleged that he was "maliciously and sadistically" assaulted "[w]ithout any provocation" by a corrections officer. Mr. Wilkins claimed that as a result of the assault he sustained heel and lower back pain, increased blood pressure, migraine headaches and dizziness, depression, panic attacks, and nightmares of the assault. The district court, on its own motion, dismissed the complaint for failure to state a claim. In a motion for reconsideration, Mr. Wilkins stated that he was unaware that the failure to allege medical treatment might prove fatal to his claim. The district court denied Mr. Wilkins leave to amend his complaint. The U.S. Court of Appeals for the Fourth Circuit affirmed.

Question

Did the Fourth Circuit err when it required a showing of "significant injury" in order to state an excessive force claim?