Simpson v. Little, et al., No. 20-5109 (10th Cir. 2021)
Annotate this CaseThis case arose from the fatal shooting of Logan Simpson by Jon Little, a patrol officer for the City of Bixby, Oklahoma. Tiffany Simpson, Logan Simpson’s mother and personal representative of his estate, sued Officer Little in his individual capacity under 42 U.S.C. 1983 for excessive force in violation of Simpson’s Fourth and Fourteenth Amendment rights. Officer Little moved for summary judgment on qualified immunity grounds. The district court denied the motion. Officer Little appealed. After review, the Tenth Circuit affirmed, finding: (1) the Court lacked interlocutory appellate jurisdiction to review the district court’s conclusion that a jury could find a constitutional violation because Officer Little challenged the factual basis for the court’s determination; (2) the Court also lacked jurisdiction to consider some of Officer Little’s arguments regarding clearly established law; and (3) the Court found his remaining arguments lack merit.
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