In the case of Jamey L. Wilkins v. Officer Gaddy, 2009, the U.S. Supreme Court ruled in favor of a prisoner who claimed he was assaulted by a correctional officer and suffered physical injuries as a result. The lower courts had dismissed his claim because they believed that his injuries were not serious enough to warrant constitutional concern under the Eighth Amendment's prohibition against cruel and unusual punishment. However, the Supreme Court disagreed with this interpretation stating that it is not necessary for an inmate to demonstrate significant injury from an excessive force claim but rather if force was applied maliciously or sadistically for purposes of causing harm then it violates contemporary standards of decency regardless of whether significant injury is evident or not.

In the dissenting opinion for Jamey L. Wilkins v. Officer Gaddy, Justice Clarence Thomas argued that the majority's decision to remand the case back to lower courts was unnecessary and inconsistent with precedent. He contended that previous rulings had established a clear standard for excessive force claims: whether force applied caused injury so severe and was applied in such an unnecessary manner as to amount to punishment or express intent to harm. According to him, Wilkins' allegations did not meet this threshold because he only claimed minor injuries from being slammed into a concrete bunk - not enough evidence of malicious intent or punitive action by Officer Gaddy. Therefore, Thomas believed it should have been dismissed outright instead of sent back down for further proceedings.