Bishop v. Deputy Dale Glazier, et al., No. 12-2661 (8th Cir. 2013)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983 alleging that the deputy sheriff used excessive force against him. The court concluded that precedent in place at the time of this incident suggested that the presence of only de minimus injuries could preclude a claim for excessive force. In this instance, the amount of force that the sheriff used did not cause more than de minimus injury. Therefore, the sheriff was entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights under the Fourth Amendment. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the sheriff.
Court Description: Civil case - Civil Rights. At the time of the incident involved here, a reasonable officer could have believed that as long as he did not cause more than de minimis injury to an arrestee, his actions would not violate the Fourth Amendment; even if the court accepts plaintiff's version of the officer's actions as true, the force the officer used did not cause more than de minimis injury, and the officer is entitled to qualified immunity because he did not violate plaintiff's then clearly established constitutional rights under the Fourth Amendment.
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