Vanderhoef v. Dixon, No. 18-5993 (6th Cir. 2019)Annotate this Case
Vanderhoef crashed his Ford Mustang into Dixon’s vehicle. Dixon, an off-duty, part-time reserve Maryville, Tennessee police officer, responded by holding Vanderhoef and his passengers at gunpoint for about two minutes. Keller let them go after a bystander threatened to call the police. A jury found that Dixon violated Vanderhoef’s Fourth Amendment rights (42 U.S.C. 1983). The district court set aside the jury’s verdict, ruling that Dixon was entitled to qualified immunity because no clearly established law put him on notice that doing what he did was unconstitutional. The Sixth Circuit reversed. The facts presented at trial adequately established a violation of plaintiff’s constitutional rights to be free from excessive force and unreasonable seizure under the Fourth Amendment. At the time of this accident and confrontation, Dixon should have known that pointing his gun at a non-fleeing teenager whom he did not reasonably suspect of any prior crime beyond speeding and reckless driving and holding him at gunpoint for roughly two minutes, violated the plaintiff’s Fourth Amendment rights.