Kingsley v. Hendrickson, 135 S. Ct. 2466

Michael Kingsley, a pretrial detainee in a Wisconsin jail, refused orders to remove paper covering a light; officers handcuffed and moved him to a receiving cell.
During removal, officers placed a knee on Kingsley’s back and Degner applied a Taser to Kingsley’s back for ~5 seconds; Kingsley alleged additional force (head slammed) that officers denied.
Kingsley sued under 42 U.S.C. § 1983 alleging violation of the Fourteenth Amendment’s Due Process Clause (excessive force). District Court denied summary judgment and tried the case; jury returned verdict for officers.
Seventh Circuit panel held a subjective standard (intent/reckless disregard) required; one judge dissented favoring an objective standard. Courts of Appeals were split on the question.
The Supreme Court granted certiorari to decide whether a pretrial detainee must prove subjective awareness that force was unreasonable or only objective unreasonableness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for excessive-force claims by pretrial detainees — subjective vs. objective	Kingsley: only objective unreasonableness is required (no need to prove officers subjectively knew force was excessive)	Respondents: plaintiff must show subjective intent or malicious/sadistic purpose (or reckless subjective awareness)	Court held objective standard governs: plaintiff must show force purposely/knowingly used was objectively unreasonable (no subjective intent element required)
Lawfulness of jury instruction using “reckless” and requiring reckless disregard	Kingsley: instruction improperly imposed subjective recklessness requirement and confused jury	Respondents: any instructional error was harmless; Solicitor General argued instruction effectively embodied objective factors	Court held the instruction was erroneous (it inserted a subjective "reckless" element); remanded to court of appeals to decide harmlessness

County of Sacramento v. Lewis, 523 U.S. 833 (discusses required mental state for due‑process liability)
Daniels v. Williams, 474 U.S. 327 (negligent infliction of harm not sufficient for due process)
Bell v. Wolfish, 441 U.S. 520 (pretrial detainees protected from conditions amounting to punishment; objective review for relation to legitimate purpose)
Graham v. Connor, 490 U.S. 386 (objective reasonableness standard for excessive force in Fourth Amendment context; relevant framework)
Block v. Rutherford, 468 U.S. 576 (applies Bell’s objective review to jail policies)
Schall v. Martin, 467 U.S. 253 (similar application of objective relation to legitimate purpose)
United States v. Salerno, 481 U.S. 739 (punitive vs regulatory distinction; objective relation test)
Whitley v. Albers, 475 U.S. 312 (Eighth Amendment excessive-force analysis in prison‑riot context)
Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment: force applied maliciously and sadistically vs. legitimate use)
Johnson v. Glick, 481 F.2d 1028 (Second Circuit factors for excessive-force analysis)