Hudson v. McMillian

In the early morning hours of 30 October 1983, Keith J. Hudson, an inmate at the Angola state penitentiary in Louisiana, got into an argument with corrections security officer Jack McMillian. With the help of coworker Marvin Woods, McMillian placed Hudson in handcuffs and shackles, removed him from his cell, and took him to an "administrative lockdown" area. According to Hudson, as he was being led to the administrative lockdown area, Woods held Hudson while McMillian punched Hudson in the mouth, eyes, chest, and stomach. Hudson also claimed that Woods also kicked and punched him from behind and that Arthur Mezo, the supervisor on duty, watched the beating and told the officers "not to have too much fun." Hudson suffered minor bruises on his body, facial swelling, loosened teeth, and a cracked dental plate.

Hudson sued Mezo, McMillian, and Woods in a federal district court. Hudson asked for damages, claiming that he had been subjected to cruel and unusual punishment and that his civil rights had been violated. The parties agreed to try the case before a magistrate, who found that the use of force was unnecessary and that Mezo had condoned the actions of McMillian and Woods. The magistrate awarded Hudson $800, and the correctional officers appealed. The Court of Appeals for the Fifth Circuit reversed, holding that Hudson had no claim because his injuries were minor and did not require medical attention. Hudson applied to the U.S. Supreme Court for a writ of certiorari, and the High Court agreed to take the case.

In a 7-2 decision, the High Court reversed the appeals court, holding that Hudson's claim of cruel and unusual punishment did not hinge on whether he had suffered a serious physical injury. Justice O'Connor, writing for the majority, cited the case of Whitley v. Albers (1986) as precedent. In that case, an inmate was shot by a guard in a prison riot, and the Court ruled that "the unnecessary and wanton infliction of pain . . . constitutes cruel and unusual punishment." The Whitley Court added that "unnecessary and wanton infliction of pain" varies according to the constitutional violation alleged by the prisoner. In a case where the prisoner alleges that officials have failed to give medical attention, for example, the proper inquiry is whether the officials exhibit "deliberate indifference" to the medical needs of the prisoner.