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Law School Case Brief

Kingsley v. Hendrickson - 135 S. Ct. 2466 (2015)

Rule:

Regarding the standard that a pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable, a court (judge or jury) cannot apply this standard mechanically. Rather, objective reasonableness turns on the facts and circumstances of each particular case. A court must make this determination from the perspective of a reasonable officer on the scene, including what the officer knew at the time, not with the 20/20 vision of hindsight. A court must also account for the legitimate interests that stem from the government’s need to manage the facility in which the individual is detained, appropriately deferring to policies and practices that in the judgment of jail officials are needed to preserve internal order and discipline and to maintain institutional security. 

Facts:

Plaintiff Michael Kingsley filed a lawsuit under 42 U.S.C.S. § 1983 in federal district court against defendants Stan Hendrickson and Fritz Degner, who were staff members of a Wisconsin county jail. Kingsley claimed that while he was in the jail as a pretrial detainee, he was forcibly transferred by defendants to a new cell, which included the application of a taser. At trial, the district court instructed the jury that Kingsley was required to prove, inter alia, that defendants "recklessly disregarded" his safety and "acted with reckless disregard" his rights. The jury found in defendants' favor. Kingsley appealed, arguing that the jury instruction did not apply the objective unreasonableness standard. The court of appeals affirmed, holding that he law required a subjective inquiry into defendants' states of mind, that is, whether they actually intended to violate, or recklessly disregarded, Kingsley's rights. Kingsley was granted a writ of certiorari.

Issue:

Did the jury instructions suggesting that the jury should weigh defendants' subjective reasons for using force adhere to the proper standard for judging a pretrial detainee's excessive force claim, namely, objective unreasonableness?

Answer:

No.

Conclusion:

The Supreme Court of the United States vacated the appellate court's judgment and remanded the case for further proceedings. The Court held that Kingsley had to show only that the force purposely or knowingly used against him was objectively unreasonable because this standard was consistent with the Court's precedent. An objective standard was workable, and the use of an objective standard adequately protected an officer who acted in good faith. Remand was warranted on the 42 U.S.C.S. § 1983 excessive force claim because the jury instructions were erroneously instructed the jury to weigh defendants' subjective reasons for using force, and the question whether that error was harmless could depend in part on the detailed specifics of the case.

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