Case Citator › Wilkins v. Gaddy

Wilkins v. Gaddy

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
559 U.S. 34
Decided
Confirmed treatments
4
Flagged citations read
334 of 334
Citing cases (total)
2,153
Treatment dates
2013–2015
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Wilkins v. Gaddy is limited among the reviewed cases: all 334 flagged citations have been read, with the 4 confirmed treatments listed below. Three Fourth Circuit opinions held that Wilkins does not apply retroactively in qualified-immunity analysis to force that predated the decision.
More on how this was screened

The Fourth Circuit also declined to extend Wilkins's rejection of an injury threshold from excessive-force claims to deliberate-indifference claims. The other reviewed opinions followed or applied Wilkins, used history parentheticals explaining that Wilkins displaced older circuit precedent, addressed unrelated treatment language, or rejected arguments that Wilkins abrogated precedent governing different claims.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

2,153 later cases cite Wilkins v. Gaddy; 334 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Wilkins v. Gaddy?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Fourth Circuit held that Wilkins applies only prospectively in qualified-immunity analysis and cannot be imputed to an officer whose conduct predated the decision.

    Hill v. Crum · Fourth Circuit · filed

    Although Wilkins abrogated Noman in 2010, Wilkins can only be applied prospectively in the context of a qualified immunity analysis.
    Read the full opinion on CourtListener →

  • In an unpublished decision, the Fourth Circuit held that a force claim arising before Wilkins and the officer's qualified-immunity defense remained governed by the circuit's pre-Wilkins injury-threshold cases.

    Williams v. Calton · Fourth Circuit · filed

    Three days after Williams filed his initial complaint, however, the Supreme Court handed down Wilkins v. Gaddy, 559 U.S. 34 (2010), abrogating Norman and stating that there was no injury threshold for excessive force claims. However, because “Norman and its progeny were controlling in the Fourth Circuit” when the incident in this case occurred, Williams’ excessive force claim and Calton’s qualified immunity defense must be analyzed under the standards established by those cases.
    Read the full opinion on CourtListener →

  • The Fourth Circuit declined to extend Wilkins's rejection of an injury threshold for excessive-force claims to Eighth Amendment deliberate-indifference claims.

    Danser v. Stansberry · Fourth Circuit · filed

    We do not discern anything in the Wilkins decision that casts doubt on our requirement that an inmate show a significant injury in deliberate indifference cases, as opposed to excessive force cases such as Wilkins.
    Read the full opinion on CourtListener →

  • The Fourth Circuit held that qualified immunity for force predating Wilkins is determined under the clearly established pre-Wilkins law, including the circuit's displaced injury-threshold rule.

    Ussery v. Mansfield · Fourth Circuit · filed

    We have subsequently concluded, however, that where the alleged use of force occurred prior to Wilkins, a defendant’s entitlement to qualified immunity turns on whether that force “was objectively reasonable in view of the clearly established law at the time of the alleged event” -- i.e., the law as set forth in Norman.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

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