## Facts

- Michael B. Kingsley was a pretrial detainee in the Monroe County Jail in Wisconsin.
- Jail staff ordered Kingsley to remove paper covering the light above his bunk; he repeatedly refused.
- Officers decided to remove the paper and move Kingsley to another cell; during the move, officers pulled him to his feet when he did not stand as ordered, and his feet struck a bed frame.
- In the new cell, Kingsley alleged that while officers attempted to remove his handcuffs, one officer placed a knee in his back, “smashed” his head into a concrete bunk, and another officer used a taser on his back.
- Kingsley sued several officers under 42 U.S.C. § 1983, claiming excessive force in violation of the Fourteenth Amendment’s Due Process Clause.

## Issues

1. Whether a pretrial detainee asserting excessive force under § 1983 and the Fourteenth Amendment must prove officers’ subjective recklessness, or instead must show only that force purposely or knowingly used was objectively unreasonable.

## Decision

- The Supreme Court reversed and remanded in a 5–4 decision.
- The Court held that a pretrial detainee must prove only that the force purposely or knowingly used was objectively unreasonable.
- The Court ruled that jury instructions requiring proof the officers “recklessly disregarded” the detainee’s rights misstated the governing standard.
- The judgment for the officers was vacated and the case was remanded for further proceedings.

## Legal Principles

- A pretrial detainee’s excessive-force claim under the Fourteenth Amendment turns on whether the force purposely or knowingly used was objectively unreasonable, not on the officer’s subjective awareness that the force was unreasonable.
- Objective reasonableness is assessed from the perspective of a reasonable officer on the scene, considering what the officer knew at the time and the government’s legitimate interests in jail order, discipline, and security.
- Relevant (non-exhaustive) factors include: the need for force versus the amount used; the extent of injury; efforts to temper or limit force; the severity of the security problem; the threat reasonably perceived; and whether the detainee was actively resisting.
- The Due Process Clause protects pretrial detainees from “punishment,” which may be shown by objective evidence that the challenged use of force was excessive in relation to a legitimate governmental objective.

## Conclusion

The Court established that pretrial detainees may prevail on § 1983 excessive-force claims by showing that force purposely or knowingly applied was objectively unreasonable under the circumstances, and that requiring proof of officers’ subjective recklessness is error.


Kingsley v. Hendrickson, 576 U.S. 389 (2015)