The plaintiff, Michael Kingsley, was a pretrial detainee in a Wisconsin County jail. In the course of moving Kingsley into a new cell, Officer Hendrickson directed Officer Degnen to stun Kingsley with a Taser, which Degnen did while Kingsley was handcuffed. The officers then left Kingsley handcuffed in his cell for about 15 minutes. The officers did not dispute that they acted purposefully or knowingly when using force against him. Instead, the officers’ position was that the force was reasonable.
Kingsley filed a § 1983 claim against the officers, claiming that they used excessive force against him in violation of the Fourteenth Amendment’s Due Process Clause. The jury found in the officers’ favor. On appeal, the sole issue before the United States Supreme Court was whether the instructions given to the jury properly stated the standard required for a finding of “excessive force.” The officers argued that a subjective standard must be used: that Kingsley had to show that the officers were subjectively aware that their use of force was unreasonable. Kingsley argued that the standard was objective reasonableness.
The Court agreed with Kingsley, and in doing so, clarified that a pretrial detainee need only establish that the force purposely or knowingly used against him was “objectively reasonable.” As a result, the Court said, “[a] court must make a determination from the perspective of a reasonable officer on the scene, including what the officer knew at the time, not with the 20/20 vision of hindsight” and must also “account for the legitimate interests that stem from [the government’s] need to manage the facility in which the individual is detained, appropriately deferring to policies and practices that in th[e] judgment of jail officials are needed to preserve internal order and discipline and to maintain institutional security.” (internal citations omitted) The Court further stated that the following may be relevant considerations in determining the reasonableness of the force: (1) the relationship between the need for the use of the force and the amount of force used; (2) the extent of the plaintiff’s injury; (3) any effort made by the officer to temper or to limit injury; (4) any effort made by the officer to temper or to limit the amount of force; (5) the severity of the security problem at issue; (6) the threat reasonably perceived by the officer; and (7) whether the plaintiff was actively resisting.
Based on this decision, the Court determined that the jury instructions were erroneous and remanded the decision for further proceedings.