Estate of De'Angelo Brown v. E.C. West, No. 22-1763 (8th Cir. 2023)
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Plaintiff was a passenger in a car that led West Memphis Police Department (WMPD) officers on a dangerous chase. He was shot and killed when officers tried to stop the car, and his estate sued them under 42 U.S.C. Section 1983 for excessive force and state-created danger. The district court granted summary judgment to the officers.
The Eighth Circuit affirmed. The court explained that it is undisputed that Plaintiff had his hands up. And the court has no doubt that shooting into the car posed a substantial risk of serious bodily harm to him. But the driver had just led police on a reckless, high-speed chase, which involved swerving into oncoming traffic, hitting a police car, and resisting efforts to stop the car by other means. By the time officers started shooting, the car had run over one officer’s legs and was headed toward others. Here, the court wrote that all things considered, officers acted reasonably in using deadly force, and the district court didn’t err in granting summary judgment.
Court Description: [Kobes, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Civil case - Civil rights. All things considered, the officers acted reasonably in using deadly force, and the driver, not the officers, put the estate's decedent in a position of extreme danger by fleeing and refusing to end the chase and by driving over one officer and driving towards the officers involved in the shooting; defendants' summary judgment is affirmed.
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