Danley v. Allen
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Kingsley v. Hendrickson displaced Danley's subjective “maliciously and sadistically” standard for a pretrial detainee's excessive-force claim, as the Eleventh Circuit recognized in Piazza v. Jefferson County. Danley's separate holdings concerning pepper spray, inadequate decontamination, serious medical needs, supervisory causation, and force used after resistance ends remain in regular use. The other opinions applied those surviving holdings or copied history parentheticals reporting Iqbal's or Kingsley's intervening acts.
187 later cases cite Danley v. Allen; 81 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 Danley v. Allen?
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
Overruled in part
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The Supreme Court's universal Rule 8 plausibility standard displaced Danley's special heightened pleading requirement for Section 1983 claims against officials asserting qualified immunity.
Ashcroft v. Iqbal · Supreme Court of the United States · filed
To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Id., at 570. A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Id., at 556. The plausibility standard is not akin to a “probability requirement,” but it asks for more than a sheer possibility that a defendant has acted unlawfully.
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Abrogated
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The Supreme Court replaced Danley's subjective excessive-force standard for pretrial detainees with a solely objective reasonableness test.
Kingsley v. Hendrickson · Supreme Court of the United States · filed
We conclude with respect to that question that the relevant standard is objective not subjective. Thus, the defendant's state of mind is not a matter that a plaintiff is required to prove. ... In short, we agree with the dissenting appeals court judge, the Seventh Circuit's jury instruction committee, and Kingsley, that a pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable.
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