Patel v. City of Madison, No. 18-12061 (11th Cir. 2020)
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Plaintiff filed a 42 U.S.C. 1983 action against the city and a police officer, alleging claims for illegal seizure, unlawful search, and excessive force in violation of the Fourth and Fourteenth Amendments to the United States Constitution. Plaintiff also alleged claims under Alabama law for illegal search, false arrest, battery, and excessive force.
The Eleventh Circuit affirmed the district court's denial of summary judgment to the officer based on qualified immunity, holding that genuine issues of material fact exist as to whether the use of force was unconstitutional. In this case, the seriousness and permanence of plaintiff's injuries and the unusual alacrity and horsepower of the officer's leg sweep preclude his force from being characterized as de minimis. Furthermore, the court held that the law had clearly established that plaintiff's force was unconstitutional where no reasonable officer could
have thought that sweeping plaintiff's legs out from under him and throwing him to the ground headfirst was a reasonable use of force. Plaintiff was somewhat frail and was not resisting or attempting to flee, and thus the law clearly forbade the officer's forceful takedown under the circumstances. Finally, the court held that the officer is not entitled to immunity under Alabama's immunity doctrine.
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