Estate of Ronald Armstrong v. The Village of Pinehurst, No. 15-1191 (4th Cir. 2016)
Annotate this CaseThe Estate of Ronald H. Armstrong appealed the district court's grant of summary judgment to the Village and members of the police department on its excessive force claims. The court held that defendants used unconstitutionally excessive force when seizing Armstrong. Had defendants limited themselves to permissible uses of force when seizing Armstrong, they would have had every tool needed to control and resolve the situation at their disposal. However, the court concluded that defendants are entitled to qualified immunity where Armstrong’s right not to be tased while offering stationary and non-violent resistance to a lawful seizure was not clearly established. Accordingly, the court affirmed the judgment.
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