
Seventh Circuit Retires “De Minimis” Standard for Use of Physical Force
In April 2008, James Washington, Jr. was a pretrial detainee at a Wisconsin jail when a guard, John P. Hively, allegedly fondled his “testicles and penis through [his] clothing” during a pat-down, “then while strip-searching him fondled his nude testicles for two or three seconds.” Washington filed a federal lawsuit against Hively, who denied the