Supreme Court of the United States
Whitley v. Albers
March 4, 1986475 U.S. 312
Summary
Justice O'Connor's opinion for the Court held that force used to quell a prison disturbance posing significant safety risks violates the Eighth Amendment when applied maliciously and sadistically to cause harm, rather than in a good-faith effort to restore discipline. The evidence could not support a finding of wantonness in the rescue plan or the shooting of Albers, so the officials were entitled to a directed verdict. In these circumstances, substantive due process provided no greater protection, and the Court did not reach qualified immunity. Justice Marshall dissented, joined by Justices Brennan, Blackmun, and Stevens, arguing that the Court imposed an unjustifiably demanding intent standard and resolved factual disputes against Albers rather than allowing a jury to decide whether the force was unnecessary and wanton. Stevens did not join the dissent's footnote addressing the independent due process claim.
Holding
- The Eighth Amendment standard for force used during a dangerous prison disturbance.. The inquiry is whether force was applied in a good-faith effort to maintain or restore discipline or maliciously and sadistically for the purpose of causing harm; deliberate indifference is not the governing standard in this setting.
- Whether Albers presented sufficient evidence of unconstitutional force to reach a jury.. The officials were entitled to a directed verdict because the evidence did not support a reliable inference that the rescue plan or the shooting constituted wanton infliction of pain.
- Whether substantive due process independently protected Albers against the challenged shooting.. Although Albers preserved a substantive due process claim, the Due Process Clause afforded him no greater protection than the Eighth Amendment in these circumstances.
Docket 84-1077