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Law School Case Brief

Hudson v. McMillian - 503 U.S. 1, 112 S. Ct. 995 (1992)

Rule:

Whenever prison officials stand accused of using excessive physical force in violation of the Cruel and Unusual Punishments Clause of the United States Constitution, the core judicial inquiry is whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.

Facts:

Petitioner Keith J. Hudson, a prisoner in a Louisiana state prison, filed a lawsuit in federal district court under 42 U.S.C.S. § 1983 against defendants Jack McMillian, Marvin Woods, and Arthur Mezo, who were security officers at the prison. Hudson claimed that he suffered bruises, facial swelling, loosened teeth, and a cracked dental plate as result of being beaten by McMillian and Woods. Hudson further claimed that the beating took place while he was handcuffed and shackled following an argument with McMillian, and that Mezo, a supervisor on duty, watched the beating but merely told McMillian and Woods "not to have too much fun." After a trial, a magistrate judge found that that McMillian and Woods used force when there was no need to do so and that Mezo expressly condoned their actions. The court ruled that defendants violated the Eighth Amendment's prohibition on cruel and unusual punishments, and awarded Hudson damages. On defendants' appeal, the court of appeals reversed, holding, inter alia, that Hudson could not prevail because his injuries were "minor" and required no medical attention. Hudson was granted a writ of certiorari.

Issue:

Did the court of appeals err in holding that Hudson could not prevail on his claim of cruel and unusual punishment against defendants because the injuries inflicted were minor and required no medical attention?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States reversed the court of appeals' decision. The Court rejected the rule that an inmate such as Hudson was required to demonstrate the existence of a "significant injury" before he could prevail on a claim of cruel and unusual punishment. Noting that the Eighth Amendment prohibited the unnecessary and wanton infliction of pain, the Court held that prison officials such as defendants inflicted cruel and unusual punishment if they used force maliciously and sadistically to cause harm, rather than in a good-faith effort to maintain or restore discipline, regardless of whether significant injury resulted.

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