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
- 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.