Case Citation: Wilkins v. Gaddy, 130 S.Ct. 1175, 175 L.Ed.2d 995 (2010)
Parties: Jamey L. Wilkins, Petitioner Officer Gaddy, Defendant Facts: North Carolina state prisoner, Jamey Wilkins, filed a claim in federal district court alleging that corrections officer, Mr. Wilkins, used excessive force against him. Because of the incident, Wilkins suffered injuries consisting of lower back pain, increased blood pressure, panic attacks, nightmares, and migraines.
Procedural History: In March 2008, the petitioner filed a pro se claim in the United States District Court for the Western District of North Carolina pursuant to 42 U.S.C. §1983. The District Court dismissed the action stating Wilkins failed to state a claim and later denied
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The Court reaffirmed its holding as in Hudson v. McMillian in that a showing of significant injury should not have been a threshold requirement for the excessive force claim, but rather whether or not the force was applied in a good-faith effort in order to maintain discipline. The petitioner did state a claim under §1983 for use of excessive force.
Reasoning: In determining what equated to a showing of significant injury, the Court referenced Hudson in that even though the petitioner’s injuries were minor and may not have required medical attention, they erred in denying the furtherance of his claim. As in Hudson, Wilkin’s injuries may have been considered so minor that they did not warrant relief, nevertheless not excusing the unnecessary force in the treatment of prisoners.
In reversing the decision of the district court, the Court held the “core judicial injury” was “whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.” The extent of injury Wilkin’s suffered may have been relevant in determining the level of force that was applied but just because the prisoner may have escaped serious injury does not prohibit the individual from pursuing a