James v. New Jersey State Police, No. 18-1432 (3d Cir. 2020)
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Stephens called 911 and reported that Gibbons hit her and had a gun in his truck. The police responded. Stephens obtained a temporary restraining order, prohibiting Gibbons from possessing firearms and from returning to Stephens’s house. The next day, Gibbons went to Stephens’s house. Stephens was talking on the phone; the friend called the police. Gibbons left Stephens’s house. Trooper Conza arrived. Stephens stated that Gibbons had waved a gun throughout their argument. Conza told Stephens to go to the police barracks and reported over the radio that Gibbons had brandished a firearm. Conza, with Troopers Bartelt and Korejko, visited the nearby home of Gibbons’s mother, James. James stated that she did not know where Gibbons was and that he might be off his schizophrenia medication. While driving to the barracks, Stephens saw Gibbons walking alongside the road and called 911. The Troopers responded. Bartelt parked his car and, exiting, observed that Gibbons was pointing a gun at his own head. Bartelt drew his weapon, stood behind his car door, and twice told Gibbons to drop his weapon. Gibbons did not comply. Bartelt shot Gibbons twice within seconds of stopping his car. Gibbons died that night.
In James’ suit under 42 U.S.C. 1983, the Third Circuit held that Bartelt is entitled to qualified immunity because he did not violate Gibbons’s clearly established rights. Bartelt’s pre-standoff knowledge of Gibbons differs from that of officers involved in cited cases. Bartelt could reasonably conclude that Gibbons posed a threat to others.
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