(CN) – A defendant need not “show significant injury in order to state an excessive force claim,” the Supreme Court ruled Monday, reinstating a North Carolina inmate’s claim that he was “maliciously and sadistically assaulted” by a corrections officer.
Jamey Wilkins said the officer, referred to only as Gaddy, “snatched [him] off the ground and slammed him onto the concrete floor” after Wilkins asked for a grievance form. Gaddy “then proceeded to punch, kick, knee and choke [Wilkins] until another officer had to physically remove him from [Wilkins],” according to the prisoner’s pro se lawsuit.
The district court dismissed the case, saying Wilkins never claimed that his injuries required medical attention.
But Wilkins said he suffered several injuries from the attack, including a bruised heel, lower back pain, migraine headaches, dizziness and psychological trauma. He filed a motion for reconsideration, attaching medical records that purportedly corroborated his injuries and treatment.
The district judge refused to reconsider the case, ruling that some of Wilkins’ alleged injuries were “pre-existing conditions,” while others were too minimal to warrant a claim for excessive force.
The high court reversed, citing its 1992 decision in Hudson v. McMillian, which held that “the use of excessive physical force against a prisoner may constitute cruel and unusual punishment [even] when the inmate does not suffer serious injury.”
“Injury and force … are only imperfectly correlated,” the justices wrote, “and it is the latter that ultimately counts.”
They found the district court’s ruling “at odds with Hudson‘s direction to decide excessive force claims based on the nature of the force rather than the extent of the injury.”
The Supreme Court sent the case to the 4th Circuit Court of Appeals in Richmond, Va.