LaChance v. Town of Charlton, No. 20-1103 (1st Cir. 2021)
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The First Circuit affirmed in part and vacated in part the judgment of the judgment of the district court granting summary judgment to Defendants - police officers and their employer - on the basis of qualified immunity in this case alleging, among other things, excessive force pursuant to 42 U.S.C. 1983, holding that the district court erred in granting Defendants' motion for judgment as a matter of law.
Plaintiff sued the officers who pushed him onto a sofa-recliner, which toppled over, and who then kneeled on his back. The district court concluded that the push and the kneel constituted two discrete uses of force, granted summary judgment on the basis of qualified immunity to Defendants as to the push, and entered a directed verdict for Defendants on the remaining counts, finding that Plaintiff failed to prove that any injury he suffered was caused by the kneel. The First Circuit vacated the judgment in part, holding (1) the push was not a clearly established violation of Plaintiff's right to be free of unreasonable seizures; but (2) there was enough evidence from which a reasonable jury could have found that it was more likely than not that the kneel caused Defendant some additional injury.
The court issued a subsequent related opinion or order on March 9, 2021.
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