Kingsley was arrested and detained in a county jail pending trial. Officers forcibly removed Kingsley from his cell after he refused to comply with instructions to remove a piece of paper that was covering the light fixture above his bed. Kingsley later filed a lawsuit under 42 U.S.C. § 1983, alleging the officers used excessive force against him, in violation of the Fourteenth Amendment’s Due Process Clause when they removed him from his cell.
The district court instructed the jury that to prevail, Kingsley had to establish the officers acted with malice and intended to harm Kingsley when they used force against him, a subjective standard. Kingsley disagreed, arguing the correct standard for judging a pretrial detainee’s excessive force claim is objective reasonableness.
In lawsuit for excessive use of force brought by a pre-trial detainee, whether the detainee must show the officers were subjectively aware their use of force was unreasonable, or only that the officers’ use of that force was objectively unreasonable.
The appropriate standard to apply to a pretrial detainee’s excessive force claim is objective reasonableness.
First, the Court noted this holding is consistent with precedent. In Bell v. Wolfish, the Court held a pretrial detainee could prevail on an excessive force claim by providing objective evidence the alleged use of force was not related to a legitimate governmental objective or that the force was excessive in relation to the alleged reason for its use. Second, the Court held an objective standard is “workable,” as many facilities, including the one in this case, train officers to interact with all detainees as if the officers’ conduct is subject to an objective reasonableness standard. Finally, the court held the use of an objective standard protects an officer who acts in “good faith.” The court recognized that running a detention facility is difficult and that officers facing disturbances are often forced to make split-second judgments in circumstances that are tense, uncertain and rapidly evolving. In addition, the court explained as part of the objective reasonableness analysis, it is appropriate to give deference to a facility’s policies and practices, which are in place to maintain order and institutional security.
576 U.S. ___, 135 S. Ct. 2466 (2015)