Chambers v. Pennycook, et al., No. 09-2195 (8th Cir. 2011)
Annotate this CaseAppellant brought an action against three law enforcement officers pursuant to 42 U.S.C. 1983 alleging that the officers violated his rights under the Fourth Amendment by using excessive force against him during and shortly after his arrest. At issue was whether the district court properly concluded that appellant's failure to show greater than de minimus injury was fatal to his claim and dismissed his complaint. The court affirmed the district court's summary judgment motion and held that a citizen could prove an unreasonable seizure based on an excessive use of force without necessarily showing more than de minimus injury. The court held, however, that the officers were entitled to qualified immunity because their alleged actions did not violate clearly established law in August 2005. The court further held that the district court did not abuse its discretion in denying appellant's motions for sanctions and motion for appointment of counsel.
Court Description: Civil case - civil rights. A citizen may prove an unreasonable seizure based on an excessive use of force without necessarily showing more than a de minimis injury; here, the officers were entitled to qualified immunity on plaintiff's claims that they used excessive force against him during and after his arrest as their actions did not violate clearly established law; given the state of the law in August, 2005, when plaintiff was arrested, a reasonable officer could have believed that as long as he did not inflict more than a de minimis injury on the arrestee, his actions would not violate the Fourth Amendment; district court did not abuse its discretion by denying plaintiff's motion for sanctions and his motion for appointment of counsel.
This opinion or order relates to an opinion or order originally issued on February 23, 2010.
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