Farris v. Oakland County, No. 23-1739 (6th Cir. 2024)
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In this case, the plaintiff, Kellie Farris, called 911 alleging that another woman had damaged her car. However, responding sheriff's deputies ended up arresting Farris instead. Farris alleged that during her arrest and subsequent transportation to jail, the deputies used excessive force. She also claimed that she was suicidal and that the deputies' actions were unreasonable given her state of mind.
In response, the deputies argued that they had probable cause for Farris's arrest based on corroborated eyewitness testimony and physical evidence in Farris's car. They further contended that Farris's suicidal behavior justified the level of force used to restrain and control her.
On reviewing the case, the United States Court of Appeals for the Sixth Circuit agreed with the lower court's decision to grant summary judgment in favor of the defendants. The court found that the deputies had probable cause for Farris's arrest and that the force used was minimal and reasonably necessary given Farris's behavior. The court also rejected Farris's claim that the county had an unconstitutional policy of inadequately training its deputies, finding no evidence of deliberate indifference or a pattern of excessive force.
The court noted that states may pass laws or prison policies that protect detainees' privacy or liberty more than the Constitution demands, but Farris failed to show how this was relevant to her Fourth Amendment claim.
In conclusion, the Sixth Circuit affirmed the district court's decision, ruling in favor of the deputies and the county on all counts.
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