Force against pretrial detainees
Kingsley v. Hendrickson
In brief
The Court set the standard for pretrial detainees’ excessive-force claims and wiped out the Seventh Circuit’s ruling, but it did not decide whether the jury-instruction error was harmless.
- Where it stands
- Decided
Decided 5-4 · June 22, 2015 · Opinion by Justice Breyer
- What it’s about
- Michael Kingsley, held in jail before trial, claimed jail officials used excessive force against him; the Supreme Court ruled he had to show only that they purposely or knowingly used force that was unreasonable under an objective standard, not that they believed it was excessive.
- Who it affects
- Pretrial detainees bringing excessive-force claims need to show force was purposely or knowingly used and objectively unreasonable—not that officials believed it was excessive.
Summary: written with AI from the case record.
What it's about
The Court found the jury instruction flawed, wiped out the appeals court’s ruling (vacated it), and sent the case back (remanded) for the Seventh Circuit to decide whether the error was harmless.
Kingsley brought his claim under a federal civil-rights law, 42 U.S.C. §1983, while he was held in jail before trial.
Question presented
When the plaintiff is a pretrial detainee, are the requirements of an excessive force claim satisfied by showing that the state actor deliberately used force and the use of force was objectively unreasonable?
What the Court decided
Holding
1. Under 42 U. S. C. §1983, a pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable to prevail on an excessive force claim. 2. Applying the proper standard, the jury instruction was erroneous. Taken together, the features of that instruction suggested that the jury should weigh respondents’ subjective reasons for using force and subjective views about the excessiveness of that force. Respondents’ claim that, irrespective of this Court’s holding, any error in the instruction was harmless is left to the Seventh Circuit to resolve on remand. 744 F. 3d 443, vacated and remanded.
- Result
- Vacated
The Court's reasoning
The Court said the instructions were wrong because they could lead jurors to weigh the officials’ own reasons for using force and their views about whether it was excessive. The Court’s test instead asks whether the force was objectively unreasonable.
The vote
From the opinions
“In my view, the answer is no.”
What's next
The Seventh Circuit must decide whether the jury-instruction error affected the outcome. The Supreme Court left that question to the appeals court.
Documents
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Opinion added: Kingsley
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.