The following excerpt is from Wilson v. Campbell, Case No. 1:16-cv-00534-SKO (PC) (E.D. Cal. 2017):
Constitution, the malicious and sadistic use of force to cause harm always violates the Eighth Amendment, regardless of whether or not significant injury is evident. Id. at 9-10; see also Oliver v. Keller, 289 F.3d 623, 628 (9th Cir. 2002) (Eighth Amendment excessive force standard examines de minimis uses of force, not de minimis injuries)).
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