Carpenter v. Gage, No. 11-2091 (8th Cir. 2012)
Annotate this CaseAppellant brought a civil rights action under 42 U.S.C. 1983 against two deputy sheriffs in Benton County, Arkansas, alleging that they unlawfully entered his home, detained him, employed excessive force against him, and denied him emergency medical care. Appellant also asserted a failure-to-train claim against the County and its sheriff. The district court granted summary judgment for the defendants, ruling that Carpenter had not presented sufficient evidence to prove a constitutional violation, and that the defendants were thus entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly dismissed Appellant's claim alleging an unreasonable search under the Fourth Amendment; (2) there was probable cause to arrest Appellant; (3) the deputies were entitled to qualified immunity against Appellant's excessive force claim; (4) there was insufficient evidence that Appellant's need for medical treatment was so obvious that the deputies exhibited deliberate indifference by taking Appellant to jail; and (5) the district court correctly dismissed Appellant's failure to train claim against the defendants.
Court Description: Civil case - civil rights. A reasonable police officer could have believed that exigent circumstances justified entering plaintiff's home without a warrant, and the district court did not err in dismissing plaintiff's claim alleging an unreasonable search under the Fourth Amendment; officers had probable cause to arrest plaintiff based on dispatcher's report that he had assaulted the first responders to a possible medical emergency in the home; force used to subdue and arrest plaintiff was not unreasonable under the circumstances, and the police defendants were entitled to qualified immunity on his excessive force claim; officers were not deliberately indifferent to plaintiff's medical needs as there was insufficient evidence to show that his need for medical treatment was so obvious that they exhibited deliberate indifference by taking him to jail; as the individual officers had not violated the Constitution, the sheriff and county could not be liable for failure to train. Judge Smith, concurring in part and dissenting in part.
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