Prisoner wins first round in claim of Eighth Amendment "cruel and unusual punishment."
Michael Williams sued six employees of Oaks Correctional Facility, alleging that they assaulted him with a chemical agent, without cause, simply to assure an orderly transfer of the prisoner from his current cell to an isolation cell. The District Court dismissed Williams' Eight Amendment suit, holding in part that a prisoner cannot sue for a "de minimis" injury. The Sixth Circuit reversed, noting that under established law, a prisoner always has an Eight Amendment Claim, despite the severity of his injury, if he can prove that a chemical agent "was NOT applied in a good-faith effort to maintain or restore discipline." The Constitution proscribes unnecessary and wanton infliction of pain against prisoners, who must meet both an objective and a subjective test to pursue a claim. Prisoners must show that prison officials did not act in subjective good faith, as described above, and that, objectively, the guards acted in a manner "resonponsive to contemporary standards of decency." Williams met this threshold requirement with his allegations: under our Constitution, we don't inflict pain on prisoners unless it is necessary to a good faith, reasonable purpose.