Siglar v. Hightower

What This Case Is About

Lee Andrew Siglar, a Texas prisoner, filed a § 1983 action against prison officials after a corrections officer twisted his arm and ear during a pat-down search triggered by a biscuit found in his jacket pocket. The Fifth Circuit affirmed the district court’s dismissal, holding that Siglar’s injuries were de minimis and insufficient to support either an Eighth Amendment excessive force claim or claims for mental and emotional suffering under the Prison Litigation Reform Act (PLRA).

The Facts

Siglar was stopped in the hallway of his prison unit by Officer Whitehead while returning from breakfast. Whitehead directed Siglar to stand and face the wall while she searched him. A biscuit was found in his jacket pocket. Whitehead called for backup, and Officer Nwose responded.

Without provocation, Nwose twisted Siglar’s arm behind his back and twisted his ear. Siglar’s ear was bruised and sore for three days, but he did not seek or receive medical treatment for any physical injury. There was no allegation that he sustained long-term damage. Officers Whitehead and Alexander witnessed the incident and did not intervene. Warden Hightower was sued for negligent supervision.

What the Court Decided

The Fifth Circuit affirmed dismissal as frivolous under 28 U.S.C. § 1915(e)(2). The court first confirmed that verbal abuse by a prison guard does not give rise to a § 1983 cause of action.

On the physical force claim, the court applied the standard from Hudson v. McMillian: whether force was applied in a good-faith effort to maintain discipline or maliciously and sadistically to cause harm. While the absence of serious injury does not automatically preclude relief, the Eighth Amendment excludes de minimis uses of physical force from constitutional recognition, provided the force is not “repugnant to the conscience of mankind.”

Turning to the PLRA’s physical injury requirement—which bars federal civil actions by prisoners for mental or emotional injury without a prior showing of physical injury—the court established an important standard: “the injury must be more than de minimis, but need not be significant.” The court concluded that Siglar’s bruised, sore ear lasting three days was de minimis and insufficient to support either the excessive force claim or claims for emotional or mental suffering.

Why This Case Matters for Your § 1983 Case

De minimis injuries bar prisoner excessive force claims. Under the PLRA and Eighth Amendment standards, a prisoner must show more than a trivial injury to sustain an excessive force claim. A bruised ear lasting three days does not meet this threshold.

The PLRA’s physical injury requirement. If you are incarcerated, the PLRA requires you to show a physical injury before you can recover for mental or emotional suffering. This case establishes that the injury must be more than de minimis—but this is a lower bar than “significant” injury.

Verbal abuse is not actionable. No matter how offensive, threatening, or degrading a prison guard’s verbal abuse may be, it does not by itself give rise to a constitutional claim under § 1983.

Bystander liability requires underlying excessive force. Claims against officers who witness force but fail to intervene depend on the existence of unconstitutional excessive force. If the force itself is de minimis, bystander liability claims also fail.

Key Takeaway

For prisoners bringing excessive force claims, the injury threshold matters enormously. Under the PLRA, minor, short-lived injuries such as a bruised ear lasting a few days will be deemed de minimis and will not support either an Eighth Amendment excessive force claim or a claim for mental and emotional suffering. While “significant” injury is not required, something more than fleeting discomfort with no lasting effects must be shown to state a viable claim.