Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992

Role: applied; posture: civil; prisoner's damages suit against three corrections officers; bench trial before Magistrate, $800 award; CA5 reversed for lack of "significant injury"; certiorari limited to that requirement; reversed; result: claimant-won; claim:

Uncertainty

None recorded

Misfit

Essentially the whole opinion is about the content of the Eighth Amendment, not 42 U.S.C. 1983, which is merely the vehicle; every doctrinal step (subjective component: malicious-and-sadistic; objective component: contextual, no significant-injury floor; de minimis force exception) is internal structure of deprivation.eighth-amendment that a single element block flattens. Needs the constitutional right modelled as its own "law" with elements (subjective/objective), and 1983 instances pointing into it.

The holding is the REJECTION of a proposed sub-element (significant injury), made inside a block that is also genuinely applied (blows not de minimis). Like Collins' abuse-of-power, there is no way to say "this is not a requirement" except a gloss/rule line; and unlike Collins the block cannot be made rule-announced without losing the applied holding.

An expressly reserved question (is an isolated, unauthorized assault "punishment"?) and a color-of-law-flavoured argument the Court declined to address; not-reached + gloss is the only vehicle, and it attaches to color-of-law only by the annotator's guess.

Separate opinions: Stevens and Blackmun reject the malicious-and-sadistic standard outside riots (so the `rule` line has only a bare majority rationale), Thomas/Scalia dissent would require serious injury. v1 has `scope dissent` and `opinion`, but no per-rule vote, and none of the separate opinions was quoted (quote set frozen at migration).

"Facts" mix trial testimony ("Hudson testified that...") with Magistrate findings; basis [proved] applies to the findings, but the vivid fact lines are testimony the Court recites without saying it was credited -- polarity [supports] does not distinguish testimony from finding.

Roughly half the pinned text (from offset 26525) is the dissent plus footnotes; quotes there would verify mechanically but are not the court's holding -- the notation has no majority/concurrence/dissent span markers.

interpretation

we hold that whenever prison officials stand accused of using excessive physical force in violation of the Cruel and Unusual Punishments Clause, the core judicial inquiry is that set out in Whitley: whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.

Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992 (42usc1983: author: Fable · QA: PASS (QA1, neov2/qa/cases-v1-QA1.md))

we hold that whenever prison officials stand accused of using excessive physical force in violation of the Cruel and Unusual Punishments Clause, the core judicial inquiry is that set out in Whitley: whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.

Splits into excessive force (Whitley/Hudson malicious-and-sadistic test) and conditions of confinement / medical care (Farmer v. Brennan subjective deliberate indifference test).

interpretation

When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency always are violated. See Whitley, supra, at 327. This is true whether or not significant injury is evident.

Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992 (42usc1983: author: Fable · QA: PASS (QA1, neov2/qa/cases-v1-QA1.md))

When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency always are violated. See Whitley, supra, at 327. This is true whether or not significant injury is evident.

Splits into excessive force (Whitley/Hudson malicious-and-sadistic test) and conditions of confinement / medical care (Farmer v. Brennan subjective deliberate indifference test).

interpretation

The Eighth Amendment’s prohibition of “cruel and unusual” punishments necessarily excludes from constitutional recognition de minimis uses of physical force, provided that the use of force is not of a sort “ ‘repugnant to the conscience of mankind.’”

Hudson v. McMillian — 503 U.S. 1 (1992) · Supreme Court of the United States · 1992 (42usc1983: author: Fable · QA: PASS (QA1, neov2/qa/cases-v1-QA1.md))

The Eighth Amendment’s prohibition of “cruel and unusual” punishments necessarily excludes from constitutional recognition de minimis uses of physical force, provided that the use of force is not of a sort “ ‘repugnant to the conscience of mankind.’”

Splits into excessive force (Whitley/Hudson malicious-and-sadistic test) and conditions of confinement / medical care (Farmer v. Brennan subjective deliberate indifference test).