Guitron v. Paul
2012 U.S. App. LEXIS 7132
| 7th Cir. | 2012Background
- Guitron alleges guard Paul twisted his wrist and applied force during escort to a segregation unit, causing two months of pain.
- Guitron contends Paul and Mlodzik directed him to the wall; when he refused, Paul bent and then slammed his wrist against the wall.
- Injury described as swollen, red, and skinned after Paul released the wrist at the destination cellblock.
- District court dismissed the complaint as de minimis under the Eighth Amendment after screening.
- Seventh Circuit analyzes whether the use of force in a prison security context can violate the Eighth Amendment, applying Whitley and Hudson standards.
- Court rejects treating the injury as de minimis and emphasizes evaluating force under Whitley/Hudson rather than classifying injuries as de minimis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether force used by guards violated the Eighth Amendment | Guitron argues excessive force violated the Eighth Amendment. | Paul acted in good-faith security measure and did not inflict punishable harm. | No constitutional violation; force within security context not cruel and unusual. |
| Whether the injury was de minimis to bar the claim | Injury was substantial (swelling, two months of pain) and not de minimis. | District court correctly classified the injury as de minimis. | De minimis analysis not controlling; evaluation should follow Whitley/Hudson rather than deeming injury insignificant. |
Key Cases Cited
- Whitley v. Albers, 475 U.S. 312 (U.S. Supreme Court 1986) (context of intentional vs. reasonable force in security settings)
- Hudson v. McMillian, 503 U.S. 1 (U.S. Supreme Court 1992) (whether force was in good-faith discipline or maliciously to cause harm)
- Williams v. Boles, 841 F.2d 181 (7th Cir. 1988) (anticipates no-significant-injury principle in context of excessive force)
- O'Malley v. Litscher, 465 F.3d 799 (7th Cir. 2006) (discussion of de minimis force in Seventh Circuit)
- Outlaw v. Newkirk, 259 F.3d 833 (7th Cir. 2001) (de minimis force considerations in prison context)
- DeWalt v. Carter, 224 F.3d 607 (7th Cir. 2000) (de minimis force and standards in Seventh Circuit)