Kingsley v. Hendrickson

Under a § 1983 claim, a pretrial detainee must show only that the force used against that detainee was “objectively unreasonable,” not that state actors “recklessly disregarded” detainee safety or “acted with reckless disregard” of constitutional rights.

Pre-trial detainee brought a § 1983 action against staff at a Wisconsin county jail, alleging that during a forcible transfer to a new cell, staff violated various constitutional and statutory rights. The district court instructed the jury that to find that staff used unconstitutional excessive force, the plaintiff was required to prove that the officers “recklessly disregarded” his safety and “acted with reckless disregard of his rights.” The district court granted partial summary judgment for the defendants, and the jury returned a verdict for the defendants. On appeal, the appellant suggested that the district court wrongly combined the standards for excessive force under the Eighth and Fourteenth Amendments, and as a result, provided erroneous jury instructions. The Seventh Circuit affirmed the district court’s rulings, holding that proof of intent was required to establish reckless disregard for a detainee’s rights.

The Supreme Court vacated and remanded the 7th Circuit’s decision, holding that (1) under a § 1983 claim, a pretrial detainee must show only that the force used against him was “objectively unreasonable” and (2) that therefore the jury instruction that said that the appellant was required to prove that the officers “recklessly disregarded” his safety and “acted with reckless disregard of his rights” was erroneous.