What is the test for a defendant to be released from custody without a showing of physical injury?

MultiRegion, United States of America

The following excerpt is from Valdez v. U.S. Bureau of Prisons, Case No. 1:14 cv 00334 LJO GSA PC (E.D. Cal. 2015):

while in custody without a prior showing of physical injury." 42 U.S.C. e(e). The physical injury "need not be significant but must be more than de minimis." Oliver v. Keller, 289 F.3d 623, 627 (9th Cir. 2002).

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