U.S. Appeals Court: PEPPER SPRAY.

• Position: Brief Article

Jones v. Shields 207 F.3d 491 (8th Cir. 2000). An inmate brought a pro se [sections] 1983 action against a corrections officer alleging that the officer inflicted cruel and unusual punishment by unjustly spraying him with a pepper-based chemical spray. The district court denied judgment for the officer and the appeals court reversed and remanded. The appeals court held that the officer's actions did not violate the Eighth Amendment because the spray resulted in only a de minimis injury and there was no showing that the officer's use of the spray was malicious or...