Significant injury is not required to sustain a claim of excessive force. Actual injury is required, and is supplied by the existence of a small cut of the eyelid and small scrapes of the knee and calf. The court does not discuss whether being repeatedly sprayed with chemical agents is an injury.
The defendants are entitled to qualified immunity for the plaintiff's suicide because there is no evidence showing that they were actually and subjectively aware of the risk of suicide. See: Lambert v. City of Dumas, 187 F.3d 931 (8th Cir. 1999).
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Related legal case
Lambert v. City of Dumas
|Cite||187 F.3d 931 (8th Cir. 1999)|
|Level||Court of Appeals|