Coker v. Arkansas State Police, et al., No. 12-3601 (8th Cir. 2013)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983 against the Arkansas State Police and a state trooper, claiming that the trooper used excessive force when arresting him after a high-speed chase. The court affirmed the district court's grant of summary judgment to the Arkansas State Police on the basis of sovereign immunity. Plaintiff had no cognizable claim for prospective injunctive relief against the trooper in his official capacity and plaintiff's claim was barred on the basis of sovereign immunity. However, the court could not conclude that the trooper's use of force once out of view of the dash camera was objectively reasonable as a matter of law. Rather, a reasonable jury could find that the severity of plaintiff's injuries demonstrated excessive force, particularly the trooper's decision to strike defendant using a metal flashlight after plaintiff was already on the ground and allegedly complying with the trooper's demands. Accordingly, the court reversed the district court's grant of qualified immunity to the trooper and remanded for further proceedings.
Court Description: Civil case - Civil rights. In suit alleging an Arkansas State Trooper used excessive force in securing plaintiff's arrest after a high-speed chase, the district court did not err in finding the claim against the Arkansas State Police was barred by Eleventh Amendment sovereign immunity; plaintiff had no cognizable claim for prospective injunctive relief against the trooper in his official capacity, and that claim was also barred by sovereign immunity; however, the district court erred in granting the trooper summary judgment based on qualified immunity on plaintiff's claims against him in his individual capacity as there were genuine issues of material fact regarding the trooper's actions which, if true, preclude a grant of qualified immunity; district court did not err in denying plaintiff's untimely motion to amend his complaint.
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