Crocker v. Beatty, No. 17-13526 (11th Cir. 2021)
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Plaintiff filed suit against defendant, a deputy in the sheriff's office, under 42 U.S.C. 1983, alleging that plaintiff's Fourth Amendment rights were violated when the deputy seized his iPhone after plaintiff took photos and videos of a car accident crash scene from an interstate median. The district court granted summary judgment on all of plaintiff's claims except for one, which plaintiff prevailed at trial.
The Eleventh Circuit affirmed the district court's order, holding that plaintiff's First Amendment claim is barred by qualified immunity because defendant did not violate clearly established law at the time; plaintiff's false-arrest claims fail because defendant had probable cause to arrest him because plaintiff's car was parked on a limited-access facility in violation of Florida law; and plaintiff's excessive-force claim fails on the merits and, in any event, is barred by qualified immunity. The court noted that, whether it analyzed plaintiff's excessive-force claim under the Fourteenth or Fourth Amendment, the court would reach the same result.
This opinion or order relates to an opinion or order originally issued on April 2, 2018.
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