From “Minor” to Material: Fifth Circuit Recalibrates the PLRA Physical-Injury Threshold in Morris v. Estes

1. Introduction

Background. In Morris v. Estes, No. 24-30553 (5th Cir. Aug. 15, 2025), Louisiana inmate Carnell C. Morris alleged that correctional officers Major M. Estes (now deceased) and Lieutenant Trehan used excessive force after Morris suffered a mental health episode in his cell. Having restrained him, the officers allegedly “threw him face-first into a footlocker,” producing facial injuries that prison staff immediately treated.

Procedural posture. Proceeding in forma pauperis, Morris’s complaint was screened under the Prison Litigation Reform Act (PLRA). The magistrate judge—relying on Siglar v. Hightower, 112 F.3d 191 (5th Cir. 1997)—construed Morris’s own characterization of his injuries as “minor” to mean “de minimis,” and recommended dismissal under 42 U.S.C. § 1997e(e). The district court adopted that recommendation. On appeal, Morris (by appointed counsel) challenged the dismissal.

Key issue. Whether, after the Supreme Court’s decision in Wilkins v. Gaddy, 559 U.S. 34 (2010), a prisoner’s excessive-force claim may be dismissed at screening merely because the alleged physical injury appears “de minimis.”

2. Summary of the Judgment

The Fifth Circuit reversed the dismissal and remanded for further proceedings. It held that:

The district court erred in equating the plaintiff’s description of his injuries as “minor” with the statutory bar on claims involving only de minimis injuries.
Wilkins makes clear that in Eighth-Amendment excessive-force cases the focus is on the nature of the force, not an “arbitrary quantity of injury.”
Even if § 1997e(e) still demands “more than de minimis” physical injury, Morris’s allegations—medical treatment for facial injuries—survive screening.
Punitive-damage claims are not barred by § 1997e(e), and the lower court failed to address that request entirely.

3. Analysis

A. Precedents Cited

Siglar v. Hightower, 112 F.3d 191 (5th Cir. 1997)
– First articulated that a PLRA “physical injury” must be “more than de minimis.”
– Relied heavily on then-current Eighth-Amendment doctrine that linked injury magnitude to claim viability.
Hudson v. McMillian, 503 U.S. 1 (1992)
– Established that excessive-force claims hinge on the nature of the force, not the extent of injury.
Wilkins v. Gaddy, 559 U.S. 34 (2010)
– Explicitly rejected requiring a “significant” injury and reaffirmed Hudson’s focus on force.
Gomez v. Chandler, 163 F.3d 921 (5th Cir. 1999); Edwards v. Stewart, 37 F. App’x 90 (5th Cir. 2002)
– Examples of injuries treated as more than de minimis when medical attention was required.
Hutchins v. McDaniels, 512 F.3d 193 (5th Cir. 2007)
– Held that § 1997e(e) does not bar punitive damages.

B. Legal Reasoning

1. Interplay of § 1997e(e) and Eighth-Amendment Doctrine. The panel reaffirmed that Siglar borrowed Eighth-Amendment standards to define “physical injury” under the PLRA. Because Eighth-Amendment doctrine evolved in Wilkins, rigid reliance on Siglar’s “de minimis” label is suspect.

2. Construing the Complaint Liberally. The court applied the Rule 12(b)(6) standard that, at the screening stage, factual allegations must be accepted as true and viewed favorably to the pro se prisoner. Simply calling an injury “minor” does not compel a legal conclusion that it is de minimis—particularly where medical treatment was required.

3. Punitive Damages Carve-out. Even if compensatory damages for purely mental suffering were barred, punitive damages remain available; thus, wholesale dismissal was improper.

4. Avoiding Unnecessary Constitutional Clash. The panel sidestepped fully reconciling Siglar with Wilkins, noting that even the stricter “more than de minimis” test was met on these facts. This minimalist approach protects judicial economy while hinting that a future en banc or Supreme Court clarification may be needed.

C. Impact

Practical Screening Standard. District courts within the Fifth Circuit can no longer dismiss excessive-force complaints merely because the prisoner labels his injuries “minor.” Record evidence of medical treatment, officer recognition of injury, or similar facts will likely defeat a § 1915 screening dismissal.
Narrows “de minimis” Exception. The decision erodes the utility of Siglar’s shorthand. Practitioners should expect more discovery-phase (rather than screening-phase) litigation over injury extent.
Encourages Pleading Punitive Damages. Counsel representing inmates should explicitly plead punitive damages to avoid total dismissal even when compensatory damages face PLRA hurdles.
Foreshadows Circuit Split Resolution. The opinion collects cases from the Tenth and Eleventh Circuits, signaling an emerging inter-circuit debate ripe for Supreme Court review.

4. Complex Concepts Simplified

PLRA Screening (§ 1915 and § 1915A): Court must dismiss meritless or facially insufficient prisoner suits at the earliest stage, often called “screening,” to conserve judicial resources.
Section 1997e(e) Physical-Injury Requirement: An inmate cannot recover compensatory damages for emotional or mental injuries unless he first shows a physical injury. Courts long debated how much injury is enough.
De minimis Injury: Legal shorthand for a harm so trivial that the law will not take notice of it. In the Eighth-Amendment context, examples might be minor bruises not requiring treatment.
Punitive vs. Compensatory Damages: Compensatory damages reimburse actual loss or pain; punitive damages punish willful, malicious, or reckless conduct and deter future violations. Section 1997e(e) restricts the former but not the latter.

5. Conclusion

Morris v. Estes represents a pivotal recalibration of the Fifth Circuit’s approach to § 1997e(e). While stopping short of overruling Siglar, the court harmonized PLRA screening with Wilkins, stressing that:

The nature of force predominates over the quantum of injury.
Pleading “minor” injuries does not doom an excessive-force claim at screening, especially where medical attention was required.
Punitive damages remain an available remedy notwithstanding § 1997e(e).

Going forward, plaintiffs, defense counsel, and district judges alike must engage more substantively with the facts and medical evidence before dismissing excessive-force claims. The decision both clarifies the Fifth Circuit’s stance and intensifies the national dialogue over the PLRA’s injury threshold—setting the stage for eventual Supreme Court resolution.