Huff v. Reeves, No. 20-7013 (10th Cir. 2021)
Annotate this CaseAs plaintiff-appellant Julie Huff was at the bank in early 2016, Cedric Norris entered, murdered the bank president, grabbed some money from tellers, and took Huff hostage, forcing her to drive the getaway vehicle. Police officers pursued the vehicle and were able to force it to crash. At first, Norris fired at the officers and fled in one direction while Huff fled away from him. She raised her arms and faced the officers. But they fired at her and she fell to the ground. Later, Norris came up behind her and used her body as a shield. Norris was killed in the shootout. Huff was shot at least 10 times. Huff later filed suit under 42 U.S.C. 1983 for violations of her civil rights, alleging, among other things, that Oklahoma Highway Patrol Trooper Chris Reeves used excessive force against her, in violation of the Fourth and Fourteenth Amendments. She also sued McIntosh County Sheriff Kevin Ledbetter for failure to properly train his deputies. The district court granted summary judgment to both defendants. The court found Reeves did not violate Huff’s constitutional rights because he did not shoot her intentionally. And it dismissed the claim against the sheriff on the grounds that Huff could neither demonstrate a predicate constitutional violation by one of his deputies nor identify any specific training deficiency related to the alleged violation. The Tenth Circuit affirmed the grant of summary judgment on the Fourteenth Amendment claim against Reeves and the failure-to-train claim against Sheriff Ledbetter, but reversed and remanded on the Fourth Amendment claim against Reeves. The Tenth Circuit held Huff could not invoke Fourteenth Amendment substantive due process in the circumstances of this case, and she failed to point to any additional training of Ledbetter’s personnel that could have prevented the alleged constitutional violation. But the Court concluded that Huff has presented a genuine issue of material fact on whether Reeves shot her intentionally. “And because it is clearly established in this circuit that an officer may not employ deadly force against a person who poses no threat, Reeves is not entitled to qualified immunity at this stage of the proceedings.”
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