Godawa v. Byrd, No. 14-5963 (6th Cir. 2015)
Annotate this CaseThe facts are based on video footage and Officer Byrd’s deposition. Byrd was on bicycle patrol in Elsmere, Kentucky, at 1:00 a.m. A Finish Line Bar employee approached, concerned about a man (Godawa) in the parking lot. Godawa got into a vehicle and drove around the parking lot. Byrd approached and saw a beer in the cup holder. Godawa stated that his driver’s license was not with him; declined to take a sobriety test; provided identifying information; admitted that he had consumed alcohol; then agreed to a field sobriety test. Byrd went to his bicycle to request backup. Godawa started his vehicle and began to back out of the parking spot, hitting the bicycle. Byrd yelled “Stop” multiple times, and had his gun drawn as he ran to the front of Godawa’s car. Byrd and Godawa’s car apparently came into contact—how it happened is disputed. Byrd got up and ran alongside the vehicle before shooting through the rear passenger-side window, hitting Godawa. Godawa drove away, turned around, and drove back. Byrd was in the middle of Dixie Highway with his gun drawn. He observed that Godawa was “slumped over.” Godawa’s vehicle struck a utility pole. Godawa subsequently died from the gunshot wound. The court dismissed the estate’s 42 U.S.C. 1983 excessive force claims. The Sixth Circuit reversed, finding that Byrd was not entitled to qualified immunity. A genuine dispute of material fact exists regarding the circumstances of Byrd’s impact with Godawa’s vehicle; a reasonable juror could conclude that Byrd’s use of deadly force violated Godawa’s clearly established constitutional rights.
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