Guitron v. Paul

Dist. Ct. did not err in dismissing for failure to state cause of action plaintiff-prisoner's 8th Amendment claim alleging defendants-prison guards injured his wrist after ordering him to get against wall of prison hallway during incident involving other prisoners. Plaintiff's allegations did not establish 8th Amendment claim where pleadings indicated that any injury occurred during defendants' attempt to maintain order in prison. Ct., though, rejected Dist. Ct.'s rationale that dismissal was appropriate in view of "de minimus" nature of plaintiff's injuries since: (1) Dist. Ct. could not determine severity of plaintiff's injuries at preliminary stage of lawsuit; and (2) plaintiff was not required to show significance of injury if prison guard otherwise inflicted pain maliciously or sadistically.