Malicious Force Against a Handcuffed, Compliant Inmate Violates Clearly Established Eighth Amendment Law; Deliberate Indifference Requires Proof of Subjective Knowledge — Erickson v. Gogebic County (6th Cir. 2025)

Introduction

In a published decision, the Sixth Circuit clarified the boundaries of qualified immunity for prison use-of-force and medical-needs claims under the Eighth Amendment. The case arises from a jail incident in which Deputy Sheriff Scott Voit threw inmate Randy Erickson to the ground and placed a knee on his back while Erickson was handcuffed in a holding cell. Judge Murphy, writing for a panel that included Chief Judge Sutton and Judge Bloomekatz, held that a reasonable jury could find Voit used force “maliciously and sadistically” in retaliation for Erickson’s disrespectful language and modest noncompliance, thereby violating clearly established law. Conversely, the court held that the record could not support an Eighth Amendment deliberate-indifference claim because there was no evidence Voit actually knew Erickson needed medical treatment.

The ruling affirms in part and reverses in part the district court’s denial of qualified immunity, allowing the excessive-force claim to proceed to trial while dismissing the medical-needs claim.

Summary of the Opinion

Excessive Force: The court affirmed the denial of qualified immunity. On the plaintiff’s version of events (as supported by video without audio), a jury could find that Voit threw a handcuffed, largely compliant Erickson to the ground, dragged him, and kneed him in the back for nearly a minute without a penological need. Such “malicious and sadistic” force is actionable and clearly established (Hudson v. McMillian; Cordell v. McKinney).
Deliberate Indifference to Medical Needs: The court reversed the denial of qualified immunity. There was no evidence Voit subjectively knew Erickson had a serious need for medical care—Erickson did not ask Voit for care, displayed no obvious injury, immediately stood and paced after the incident, and Voit was off-duty for the next two days until after Erickson received hospital treatment.
Disposition: Affirmed in part, reversed in part, and remanded for further proceedings consistent with the opinion.

Factual Background and Procedural Posture

Setting: Gogebic County Jail (Michigan Upper Peninsula) in February 2020, where Erickson was serving an OWI sentence.
Prelude: Voit confronted inmates about an orange peel in a hallway. Erickson retorted: “If you were doing your job, you would know who threw the orange peel,” after which Voit cancelled Erickson’s visitations for the day and walked away.
Erickson’s Outburst: Erickson kicked the cell door, mishandled the phone cord, and threw a “boat” (mattress container) toward the door, then reset items and calmed down.
Escort to Holding Cell: Voit viewed behavior on video, returned, ordered Erickson out, cuffed his hands behind his back, and escorted him to a holding cell without resistance.
In-Cell Incident (video, no audio): While facing a wall/mattress for uncuffing, Erickson placed one knee on the mattress and one foot remained on the floor. Voit suddenly threw Erickson—still handcuffed—to the ground, pulled him by neck/wrist, dragged him, and then placed his knee on Erickson’s back (below the neck) for ~40 seconds while removing cuffs. Erickson then stood and shouted.
Injuries and Aftermath: Erickson complained of pain and, two days later, was taken to a hospital. Diagnoses included back contusions and a fractured upper rib near where Voit’s knee had been placed. Erickson also claimed dental damage and chronic shoulder/wrist pain. The Attorney General prosecuted Voit (acquitted). The Sheriff suspended him, criticized his lack of “communication” and “de-escalation,” and ordered further training; Voit retired.
Litigation: Erickson sued under 42 U.S.C. § 1983, alleging excessive force and deliberate indifference. The district court denied Voit’s summary-judgment motion on qualified immunity. Voit appealed.

Legal Framework

The Eighth Amendment, incorporated against the States via the Fourteenth Amendment, forbids “cruel and unusual punishments” not only in formal sentencing but also in “informal” harms inflicted by prison staff. Two components govern these claims, but their contours vary by claim type:

Excessive Force (Hudson v. McMillian; Whitley v. Albers; Wilkins v. Gaddy):
- Subjective: Demanding. Liability arises only if the officer acted “maliciously and sadistically to cause harm,” not merely unreasonably or negligently.
- Objective: Relaxed. No need to prove “significant” injury; non-de minimis force suffices. De minimis force (like a trivial shove) typically is not actionable.
Deliberate Indifference to Medical Needs (Estelle v. Gamble; Farmer v. Brennan):
- Objective: Demanding. Plaintiff must show a “serious medical need,” either diagnosed as requiring treatment or so obvious that a layperson would recognize the need.
- Subjective: Less demanding than excessive-force’s “malice,” but still requires actual knowledge. The officer must subjectively know of, and consciously disregard, the serious medical need.
Qualified Immunity (District of Columbia v. Wesby; Rivas-Villegas v. Cortesluna):
- Two-prong test: (1) constitutional violation; and (2) the right was clearly established, meaning every reasonable officer would know the conduct was unlawful in the particular circumstances. Specificity is crucial, except in “obvious” cases.

The Court’s Analysis

A. Excessive Force

1) Constitutional Violation

The panel applied the Hudson/Whitley framework, focusing on whether an objectively modest, handcuffed inmate posed a threat justifying significant force and whether the force used was calibrated to any such need. Applying the factors:

Need for force: Erickson’s tantrum had abated. He complied with Voit’s order to exit the shared cell, accepted handcuffs, and walked calmly to the holding cell. In the holding cell, he substantially complied with instructions to kneel, lowering his body to facilitate uncuffing. A reasonable jury could find Erickson posed little to no threat while handcuffed and in a compromised position.
Proportionality: Against this minor noncompliance (one foot briefly on the floor), Voit employed significant force—throwing a handcuffed inmate down, dragging him, and kneeling on his back for ~40 seconds. A jury could find the force disproportionate to any need.
Efforts to temper: None. The Sheriff’s post-incident letter echoed this, faulting Voit’s lack of “communication” and “de-escalation.”
Injury: Erickson suffered a fractured rib and bruising and claims additional dental and musculoskeletal injuries. Such injuries support an inference of malicious intent.

The court concluded a reasonable jury could find Voit acted “maliciously and sadistically to cause harm,” particularly to punish Erickson for disrespectful language rather than to address a genuine security need.

2) Objective Non–De Minimis Force

The force used was not de minimis. Unlike trivial contact (e.g., a “karate chop” leaving no mark), Voit’s force lasted about a minute, caused pain, and resulted in a rib fracture and other claimed injuries. The conduct aligns with cases deeming similar force actionable (Hudson; Cordell).

3) Clearly Established Law

The panel offered two paths to “clearly established” status:

Obvious case under Hudson: Using non-de minimis force “maliciously and sadistically to cause harm” without penological justification is, in itself, clearly unlawful. Any reasonable officer would know this.
Materially similar precedent: Cordell v. McKinney, 759 F.3d 573 (6th Cir. 2014), squarely alerted officers that significant force against a handcuffed inmate in a holding-cell context, motivated by disrespect/language and modest noncompliance, violates the Eighth Amendment. Cordell’s facts are “materially indistinguishable”: a handcuffed inmate, an officer reacting to disrespect, significant force in a controlled setting, and an objectively verifiable injury.

The court distinguished two decisions:

Sootsman (79 F.4th 608): There, the unhandcuffed inmate made an aggressive step; the officer’s force lasted seven seconds and caused no immediate medical treatment. Here, Erickson was handcuffed and largely compliant; the force was greater in duration and effect.
Burnett v. Griffith (33 F.4th 907): Qualified immunity applied because the inmate was not “under control” and tried to escape while being escorted to suicide watch. In Erickson’s case, a reasonable jury could find the inmate was under control, aligning the case with Cordell rather than Burnett.

Result: Qualified immunity denied on the excessive-force claim.

B. Deliberate Indifference to Medical Needs

The court did not reach the objective seriousness of Erickson’s injuries because the claim failed on the subjective element. To establish deliberate indifference, Erickson had to show Voit actually knew of, and recklessly disregarded, a serious medical need. The record did not permit that inference:

No request for care was made to Voit on the day of the incident.
The injuries were not obvious in the moment (e.g., not akin to a bleeding stab or gunshot wound). After Voit left, Erickson rose immediately and paced, exhibiting no visible signs suggesting an immediate need.
Voit was off-duty the following two days; Erickson received hospital care before Voit returned.

Result: Qualified immunity granted on the medical-needs claim; the district court’s denial was reversed.

Precedents Cited and Their Influence

Hudson v. McMillian, 503 U.S. 1 (1992): Establishes that malicious and sadistic force violates the Eighth Amendment regardless of “significant injury,” but de minimis force typically does not. Central to both the violation and clearly established analysis.
Whitley v. Albers, 475 U.S. 312 (1986): Instructs courts to defer to prison officials in urgent situations and to evaluate need, proportionality, efforts to temper force, and injury—framework applied to gauge Voit’s subjective state of mind.
Wilkins v. Gaddy, 559 U.S. 34 (2010): Reinforces that the focus is on nature of force, not the extent of injury, though injury evidence can corroborate malicious intent.
Cordell v. McKinney, 759 F.3d 573 (6th Cir. 2014): Materially similar facts (handcuffed inmate, officer reacting to disrespect, significant force in a controlled setting, objective injury). Provides the “clearly established” hook for denying qualified immunity.
Leary v. Livingston County, 528 F.3d 438 (6th Cir. 2008): Example of de minimis force (a “karate chop” with no pain or mark), used as a contrast to show Voit’s force was far more than trivial.
Johnson v. Sootsman, 79 F.4th 608 (6th Cir. 2023): Demonstrates when limited, brief force against an unhandcuffed, aggressive inmate can be reasonable; distinguished based on duration, custody status, and injury.
Burnett v. Griffith, 33 F.4th 907 (6th Cir. 2022): Qualified immunity where inmate was not under control and attempted escape; distinguished because Erickson was under control.
Estelle v. Gamble, 429 U.S. 97 (1976): Foundational medical-needs case—prison officials violate the Eighth Amendment when they are deliberately indifferent to serious medical needs.
Farmer v. Brennan, 511 U.S. 825 (1994): Defines deliberate indifference as actual, subjective knowledge and disregard of a substantial risk—dispositive standard for rejecting Erickson’s medical-needs claim.
Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004); Mattox v. Edelman, 851 F.3d 583 (6th Cir. 2017); Phillips v. Tangilag, 14 F.4th 524 (6th Cir. 2021): Clarify the objective “serious medical need” prong and when a condition is obvious to a layperson; cited to show the court could assume, without deciding, seriousness but found knowledge lacking.
Heeters v. Bowers, 99 F.4th 900 (6th Cir. 2024): Example of injuries that are obviously serious; used to contrast the non-obvious nature of Erickson’s injuries at the scene.
District of Columbia v. Wesby, 583 U.S. 48 (2018); Rivas-Villegas v. Cortesluna, 595 U.S. 1 (2021): Emphasize the need for specificity in clearly established law and the limited “obvious case” exception; the panel leveraged both, noting Hudson’s obviousness and Cordell’s close factual match.
Gambrel v. Knox County, 25 F.4th 391 (6th Cir. 2022): Articulates the “materially indistinguishable” standard; used to frame Cordell’s role as controlling precedent.

Legal Reasoning in Depth

The opinion is notable for how it synchronizes the summary-judgment posture, video evidence, and the Hudson/Whitley factors:

Summary-judgment lens: Even with video, the court adhered to the rule of crediting the nonmovant's reasonable version (here, that Erickson posed little threat while compliant and handcuffed), especially where the video lacked audio and did not foreclose competing inferences about subjective threat perception.
Hudson/Whitley application: The panel’s methodical evaluation—need for force, proportionality, efforts to temper, and injury—demonstrates that significant force against a restrained inmate in a controlled setting is strongly probative of malice when not preceded by an immediate safety trigger.
Clearly established analysis: The court’s dual rationale is important doctrinally. First, it signaled that in the Eighth Amendment prison context, “malicious and sadistic” non-de minimis force can be an “obvious” violation requiring no case-on-all-fours. Second, it anchored the ruling in Cordell as a case with materially indistinguishable facts, ensuring compliance with the Supreme Court’s specificity mandate.
Medical-needs knowledge: By foregrounding the subjective, actual-knowledge requirement of Farmer, the court cabined deliberate-indifference liability to cases where the officer either is told of the need or the need is so obvious that it speaks for itself. The facts here—no request, no immediate visible impairment, and the officer’s absence from work—defeated the knowledge element.

Impact and Practical Implications

For Corrections Agencies and Officers

Use-of-force on restrained inmates: Significant force on a handcuffed, largely compliant inmate in a controlled environment (e.g., a holding cell) is high risk for personal liability. Knee-to-back pressure of meaningful duration, absent a contemporaneous safety justification, is likely to be viewed as malicious.
De-escalation matters: The Sheriff’s internal critique resonated with the court’s analysis. Documented de-escalation efforts (or lack thereof) can shape the proportionality inquiry. Training, policies, and real-time supervisory reinforcement will be key litigation safeguards.
Video is not a panacea: Video without audio or with ambiguous angles may not foreclose factual disputes about compliance, threat, or officer intent. Expect courts to draw reasonable inferences for plaintiffs at summary judgment.

For Plaintiffs’ Counsel

Excessive force framing: Emphasize the Hudson/Whitley factors and the restrained status of the inmate. Cordell remains a powerful clearly-established anchor for handcuffed holding-cell force cases.
Medical-needs proof: The hurdle is subjective knowledge. Build evidence that the officer was informed of pain, witnessed conspicuous symptoms, or had other knowledge cues (e.g., audible cries, visible deformities, or shared shift logs). Absent that, the claim risks dismissal even with objectively serious injury.

For Defense Counsel

Qualified immunity strategy: Focus on the inmate’s control status, immediacy of any safety threat, brevity of force, and efforts to temper. Distinguish from Cordell where possible. For medical-needs claims, develop proof of non-knowledge (no requests, no obvious signs, temporal gaps, off-duty periods).
Policy alignment: Demonstrate adherence to written policies and de-escalation protocols; ensure early preservation of all video/audio and incident reports to lock in the proportionality narrative.

Doctrinal Significance

The decision reinforces that “malicious and sadistic” non-de minimis force in prisons can be an “obvious” violation for qualified immunity purposes, while also satisfying the Supreme Court’s specificity requirement via Cordell.
It also tightens deliberate-indifference liability to situations with proof of actual knowledge, underscoring that injury alone—even if later diagnosed as serious—will not sustain a claim without evidence the officer knew of the need at the relevant time.

Complex Concepts Simplified

Malicious and sadistic: Force used to punish or retaliate, not to maintain or restore discipline. Think “punishment for disrespect,” not “necessary control.”
De minimis force: Trivial contact that causes no pain or mark (e.g., a fleeting shove). Not actionable under the Eighth Amendment.
Serious medical need: A condition that a doctor says needs treatment, or that is so obvious any layperson would recognize that immediate medical care is required.
Deliberate indifference: The officer actually knew about the serious medical need and consciously chose to ignore it—not mere negligence or that the need existed.
Qualified immunity: Protects officials unless they violate a constitutional right that was clearly established at the time, such that every reasonable officer would know the conduct was unlawful in the specific context.

Conclusion

Erickson v. Gogebic County draws a sharp, instructive line in Eighth Amendment jurisprudence within the Sixth Circuit. On the excessive-force side, it confirms that significant, retaliatory force used on a handcuffed, largely compliant inmate in a controlled setting is both actionable and clearly established as unlawful—particularly in light of Cordell. On the medical-needs side, it reiterates that deliberate indifference requires proof the officer actually knew of the need for treatment; the mere fact that force was used, without obvious injury or a request for care, does not suffice.

The opinion signals to correctional institutions the legal premium on de-escalation, proportionality, and documentation, and it offers litigants a clear roadmap: factual development around restraint status and threat level for excessive-force claims, and concrete evidence of officer knowledge for medical-needs claims. As a published decision, it will shape prison litigation across the Sixth Circuit and likely inform policy and training around force application in holding-cell contexts.