## Facts

- Keith J. Hudson, a Louisiana state prisoner, argued with guard Jack McMillian.
- Hudson alleged McMillian and Marvin Woods beat him while he was handcuffed and shackled.
- Hudson claimed supervisory officer Arthur Mezo observed the beating and told the officers “not to have too much fun.”
- Hudson reported minor bruises, facial swelling, loosened teeth, and a cracked dental plate.
- A magistrate found the officers used force when there was no need and that Mezo condoned the conduct; damages were awarded under 42 U.S.C. § 1983 for an Eighth Amendment violation.
- The Fifth Circuit reversed, holding Hudson had to show “significant injury” and that his injuries were too minor.

## Issues

1. Whether a prisoner bringing an Eighth Amendment excessive-force claim must prove “significant injury” to prevail.
2. Whether otherwise unconstitutional force can be exempt from Eighth Amendment scrutiny solely because resulting injuries are minor.

## Decision

- The Supreme Court reversed the Fifth Circuit (7–2) and remanded.
- The Court held that excessive physical force against a prisoner may violate the Eighth Amendment even without serious injury.
- The Court rejected a categorical “significant injury” threshold for excessive-force claims.
- The Court stated that the extent of injury is relevant evidence, but not dispositive of whether the force was unconstitutional.

## Legal Principles

- The governing standard for prisoner excessive-force claims is whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.
- The Eighth Amendment’s objective inquiry is contextual and responsive to contemporary standards of decency; in the excessive-force setting, malicious and sadistic force violates those standards even if significant injury is not evident.
- The absence of serious injury does not end the Eighth Amendment analysis, though minor injury may bear on whether the force was de minimis or instead reflected wanton infliction of pain.
- A rule requiring a minimum quantum of injury is inconsistent with Eighth Amendment protection because it would permit severe abuse so long as it falls below an arbitrary injury threshold.

## Conclusion

The Court held that prisoners need not show significant injury to establish an Eighth Amendment excessive-force violation; the central question is whether officers used force maliciously and sadistically to cause harm rather than to maintain or restore discipline, with injury serving as one evidentiary factor.


Hudson v. McMillian, 503 U.S. 1 (1992)