HUDSON v. MCMILLIAN

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Case Basics
Docket No. 
90-6531
Petitioner 
Hudson
Respondent 
McMillian
Opinion 
Advocates
(Argued the case for the petitioner)
(Argued the case for the United States as amicus curiae urging reversal )
(Argued the case for respondents)
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Facts of the Case 

Keith Hudson, a Louisiana inmate, claimed that he was beaten by Marvin Woods and Jack McMillian, two prison guards, while their supervisor, Arthur Mezo, watched. Hudson sued the guards in Federal District Court under 42 U.S.C. 1983, which allows individuals to bring suit for the "deprivation of any rights, privileges, or immunities secured by the Constitution." Hudson argued that they had violated his Eighth Amendment right to be free from cruel and unusual punishment. The District Court ruled that the guards had used force when there was no need to do so, violating the Eighth Amendment, and that Hudson was therefore entitled to damages. The Fifth Circuit Court of Appeals reversed, however, finding that an inmate must demonstrate "significant injury" when he claims that his Eighth Amendment rights have been violated by the use of excessive force.

Question 

Must an inmate alleging that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by the excessive use of force demonstrate "significant injury" to prevail on his claim?

Conclusion 
Decision: 7 votes for Hudson, 2 vote(s) against
Legal provision: Amendment 8: Cruel and Unusual Punishment

No. In a 6-to-3 decision, the Supreme Court held that the degree of injury suffered by an inmate is one of several important factors in an Eighth Amendment claim of cruel and unusual punishment, but that the absence of "significant injury" alone does not mean his rights have not been violated. Instead, the Court should consider whether the punishment inflicted was malicious and sadistic. "When prison officials maliciously and sadistically use force to cause harm, contemporary standards of decency are always violated," Justice Sandra Day O'Connor wrote in the majority opinion. "This is true whether or not significant injury is evident. Otherwise, the Eighth Amendment would permit any physical punishment, no matter how diabolic or inhuman, inflicting less than some arbitrary quantity of injury. Such a result would have been as unacceptable to the drafters of the Eighth Amendment as it is today."

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HUDSON v. MCMILLIAN. The Oyez Project at IIT Chicago-Kent College of Law. 10 November 2014. <http://www.oyez.org/cases/1990-1999/1991/1991_90_6531>.
HUDSON v. MCMILLIAN, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1991/1991_90_6531 (last visited November 10, 2014).
"HUDSON v. MCMILLIAN," The Oyez Project at IIT Chicago-Kent College of Law, accessed November 10, 2014, http://www.oyez.org/cases/1990-1999/1991/1991_90_6531.