On June 22, 2015, the Supreme Court, in the case Kingsley v. Hendrickson, Case No. 14-6368, held that to provide an excessive force claim under 42 U.S.C. Section 1983, a pretrial detainee must show only that officers' particular use of force was objectively unreasonable. The detainee does not need to show that the officers were subjectively aware that their use of force was unreasonable. The case was remanded to determine whether a jury instruction including a provision for the officers' reckless disregard of Kingsley's safety, which provided an additional requirement to be proved, constituted harmless or plain error.