Correctional officers work in close proximity to inmates, navigating a complex environment where they must anticipate and respond to potential risks. While an officer may initially encounter unexpected violence from a specific inmate, a jail’s internal communication network—through shared experience, incident reports, and staff briefings—rapidly disseminates information about an inmate’s behavior, making them “known” to the facility’s personnel. For example, an inmate’s documented history of assaultive behavior may justify heightened caution, while a record of compliance might suggest a lower threat level.

The Supreme Court was concerned that lower courts had narrowly focused on the immediate moment of a use-of-force incident.  In a correctional setting, this basis would have overlooked the broader context of an inmate’s prior behavior or interactions with correctional staff. This approach risks portraying officers as unaware of an inmate’s established patterns—such as repeated violence or resistance—despite correctional facilities’ robust communication systems, including incident reports, staff briefings, and inmate records, which make such behaviors widely known. Limiting the “totality of the circumstances” to the precise moment of force application can distort the reasonableness analysis, ignoring critical context that shapes an officer’s perception of a threat.

The landmark U.S. Supreme Court cases Whitley v. Albers (1986), Hudson v. McMillian (1992) and Kingsley v. Hendrickson (2015) have shaped the legal standards for evaluating use-of-force incidents in correctional settings. When the courts evaluate the use of force on convicted inmates, the courts utilize a subjective test. The subjective test gives great weight to the state of mind and perceptions of responsible officers.⁵   In 2015, the Supreme Court determined an objective test for force should be applied on pretrial detainees.  That test is the Fourth Amendment objective reasonableness test. “[A] pretrial detainee must show only that the force purposely or knowingly used against him was objectively unreasonable.”⁶ Unlike with convicted inmates, the officers’ intent, state of mind, and perceptions when pretrial detainees are involved are no longer important considerations.   This standard, building on Graham v. Connor (1989),⁷ evaluates reasonableness from the perspective of a hypothetical “reasonable officer” at the scene, considering the officer’s knowledge at the time, the inmate’s behavior, and the operational context of the facility. 

Interestingly, the Kingsley Court emphasized this assessment must balance the government’s legitimate interests in managing detention facilities, deferring to policies and practices deemed necessary by jail officials to maintain “internal order and discipline” and “institutional security,” as established in Bell v. Wolfish (1979).⁸ Graham v. Connor further articulated that force used by officers must be “objectively reasonable” under the Fourth Amendment, judged from the perspective of a reasonable officer at the scene, considering factors like the severity of the crime, the threat posed, and the suspect’s resistance.⁹

These Fourth Amendment rulings introduce the concept of a hypothetical “reasonable officer” as a standard for assessing every use-of-force event for pre-trial arrestees. Correctional officers must internalize this standard, as it guides judicial scrutiny in court, where opposing legal teams will debate whether the officer’s actions align with or deviate from what this hypothetical reasonable officer would have done under the same circumstances. 

While Barnes v. Felix addressed a police shooting under the Fourth Amendment, its rejection of temporal and time restrictions in the “totality of the circumstances” analysis has significant implications for correctional settings. Correctional officers, like police, rely on prior knowledge of an individual’s behavior to assess risks. For instance, an inmate who suddenly adopts an aggressive posture may be perceived as a greater threat if records show prior assaults, a factor courts must now consider under Barnes. This expanded scope ensures that the reasonableness of force reflects the real-world dynamics of jail management, where officers are not “blind” to an inmate’s history but actively informed by it.  Although often overlooked, the Kingsley Court included as part of the criteria to determine if there is a need to apply force to consider “the facts known to the officer at the time.”¹⁰  The Court wrote “[O]bjective reasonableness turns on the facts and circumstances of each particular case.’ A court must make this determination from the perspective of a reasonable officer on the scene, including what the officer knew at the time, not with the 20/20 vision of hindsight.” ¹¹

The Barnes ruling underscores the critical importance of documentation in correctional facilities, particularly in light of the totality of circumstances.  Regardless of whether an inmate is pre-trial or convicted, agencies should not disregard facts and circumstances that directly influenced an officer’s perceived threats.¹²   Officers should thoroughly document not only the immediate circumstances of a use-of-force incident but also any prior events, interactions, or patterns of behavior that shaped their perception of a threat. This may include an inmate’s history of resisting lawful orders, assaulting staff, or disrupting facility operations, potentially spanning years of documented records. 

Comprehensive documentation ensures that use of force review boards and courts can fully evaluate the “totality of the circumstances” as mandated by Barnes, bridging the gap between an officer’s subjective perception and the objective reasonableness standard and actions taken. Without such documentation, critical context may be lost, weakening an officer’s defense in § 1983 litigation. 

Correctional facilities should prioritize training officers on detailed documentation practices and maintaining robust inmate records. Training should emphasize articulating the officer’s perception of a threat, linking immediate actions to prior knowledge and facts. There are no shortcuts when communicating these factors and perceptions.  The Barnes ruling fortifies the role of understanding the factors from Kingsley and communicating the depth of perception that corrections officials have when making decisions.