Case Citator › Boxer X v. Harris

Boxer X v. Harris

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

Abrogated
Court
Eleventh Circuit
Citation
437 F.3d 1107
Decided
Confirmed treatments
1
Flagged citations read
232 of 232
Citing cases (total)
509
Treatment dates
2020
Abrogated
A reviewed court treats this case as abrogated by later authority. Boxer X v. Harris has been abrogated in part: all 232 flagged citations have been read, with the 1 confirmed treatment listed below. The Eleventh Circuit in Sconiers v. Lockhart retired Boxer X's injury-focused rule that an Eighth Amendment sexual-assault claim is not actionable without more than de minimis injury, while preserving its holding that severe or repetitive sexual abuse can violate the Eighth Amendment.
More on how this was screened

The other reviewed opinions applied Boxer X's surviving abuse or pro se-pleading rules, used treatment language for unrelated authorities, or repeated history parentheticals reporting Sconiers's act. Those later history reports do not create additional treatments.

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.

509 later cases cite Boxer X v. Harris; 232 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 Boxer X v. Harris?

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Treatments

Abrogated

  • The Eleventh Circuit held that Wilkins abrogated Boxer X's injury-focused rule that an Eighth Amendment sexual-assault claim is not actionable without more than de minimis injury, while leaving Boxer X's severe-or-repetitive-abuse holding intact.

    Kristin Sconiers v. FNU Lockhart · Eleventh Circuit · filed

    Although Boxer X’s holding that “severe or repetitive sexual abuse of a prisoner by a prison official can violate the Eighth Amendment,” remains good law, Wilkins clarified that courts cannot find excessive force claims not “actionable” because the prisoner did not suffer “more than de minimis injury.” Boxer X, 437 F.3d at 1111. As we had not previously announced this abrogation, the district court here understandably relied on Boxer X. For the reasons we have explained, though, we must now retire the abrogated portion of Boxer X. The lack of serious physical injury, considered in a vacuum, cannot snuff out Eighth Amendment sexual-assault claims.
    Read the full opinion on CourtListener →

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