Kingsley V Hendrickson

Kingsley v. Hendrickson

Lisa A. Darlington

3109650

LSTD 502

Professor James Barney

December 6, 2015

Kingsley v Hendrickson is an important case pertaining to excessive force of pre-trial detainees and how the court made it easier for plaintiffs to prove an excessive force case pursuant to 42 U.S.C § 1983. In this case, Michael Kingsley was arrested on drug charges and taken to pre-trial detention in Sparta, Wisconsin. While in detention Kingsley was given an order to remove a piece of paper he had placed over a light fixture in his cell. The deputy in the jail ordered him several times to take it down and he refused. The jail officer reported the incident to his commanding officer who ordered for Kingsley to be removed from his cell. Four police officers forcibly removed him from the cell and made him lie face down on the surface. Kingsley states the one of the officers then kneed him in the back while two other officers then slammed his head onto a concrete bunk. Kingsley stated that he was in such extreme pain that he couldn’t immediately walk. The officers testified that Kingsley resisted when they tried to remove the handcuffs. The officers then proceeded to use a Taser on Kingsley for several seconds even though he was handcuffed and lying face down. He was then left lying there for fifteen minutes before the handcuffs where removed. On these facts, Kingsley sued the officers for using excessive force. The court decided in favor of the officers and Kingsley appealed. He challenged a claim that the jury instruction was vague when requiring him to prove the officers acted recklessly. A divided court ruled in Kingsley’s favor. I believe the Supreme Court rightly decided this case for the following reasons: 1) In accordance with Graham v. Conner 490 U.S. 386 (1989), excessive force requires proof that a reasonable officer would have known the force was excessive, 2) plaintiffs need not prove officers acted maliciously to cause harm, and 3) merely using objectively reasonable force does not make a claim for a violation of the Constitution.  The legal question before the court has to do with the legal standard for finding unconstitutionally excessive force during pre-trial detention. (SCOTUS)

Excessive force requires proof that a reasonable officer would have known the force was excessive.Kingsley and the officers agreed that the intent was to handcuff to gain compliance and that a Taser was used. The question the court had to consider was rather Kingsley was required to prove that the officers objectively understood the force was excessive. They also had to decide if the plaintiff was required to show that the officers subjectively understood their actions to be excessive. (Eye of the Objective Beholder) In a 5-4, ruling the Court ruled that Kingsley need only show that a reasonable officer would have understood the force to be excessive. They stated that objective standards are easier to prove than subjective standards. Subjective standard would not advance 42 U.S.C. § 1983. 42 U.S.C. § 1983 states, “[E]very person who under color of any statute, ordinance, regulation, custom, or usage, of any state or territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.”  To be victorious in a claim under section 1983, the plaintiff must prove two critical points: a person subjected the plaintiff to conduct that occurred under color of state law, and this conduct deprived the plaintiff of rights, privileges, or immunities guaranteed under federal law or the U.S. Constitution.(legal dictionary)The objectively reasonable standard also protects officers acting in good faith from frivolous lawsuits. The reasonableness would still be judged from the perspective of a reasonable officer acting at the time and place of the incident. The reasonable standard was set in the 1989 court case Graham v. Connor. The court decision from Graham v. Connor determines the lawfulness of every use of force decision an officer makes.The Court also restated that officers are placed in situations where they have to make split second decisions and that the prison setting is its own difficult beast.