Lippard repeatedly attempts to minimize Brown's injuries as requiring “no more than swabbing with Betadine.” But the Supreme Court has “put to rest a seriously misguided view that pain inflicted by an excessive use of force is actionable under the Eighth Amendment only when coupled with ‘significant injury,’
e.g., injury that requires medical attention or leaves permanent marks.”
Id. at 13 (Blackmun, J., concurring). While this particular injury did require medical attention, Lippard apparently prefers a pre-
Hudson standard requiring the complainant to receive
serious medical attention. There is no basis for that position.