Williams v. City of York, No. 18-3682 (3d Cir. 2020)
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A York, Pennsylvania officer reported a shooting and said the suspects fled in a vehicle. Other officers pursued the vehicle, which crashed. Officers pursued the driver and a passenger on foot. An officer found a spent .38 caliber shell casing inside the vehicle. Officers observed Williams and Scott running and ordered them to get on the ground. Scott complied but Williams ran and was eventually apprehended. Williams claims the officers were very rough with her and disregarded her complaints. According to three officers, Williams “was kicking, flailing around, being disorderly, and yelling.” At one point, she tripped on an unidentified officer’s foot. She was transported to City Hall where she continued to refuse to cooperate. Williams claims that an unidentified officer “approached her, twisted her arm, threw her against the wall, and threatened if she did not give him her arm, he would break it.”
Williams, found not guilty of disorderly conduct, sued the city and the officers under 42 U.S.C. 1983. The district court denied the officers qualified immunity. The Third Circuit reversed. A plaintiff alleging that one or more officers engaged in unconstitutional conduct must establish the personal involvement of each named defendant to survive summary judgment and district courts must specify those material facts that are and are not subject to genuine dispute and explain their materiality. Reviewing the actions attributable to identified officers, the court concluded that the officers did not violate clearly established law.
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