Flowers v. Renfro, No. 21-2675 (7th Cir. 2022)
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A man grabbed Flowers’s girlfriend in a bar. After a verbal altercation, the bar’s owner asked both men to leave. Flowers protested but left the bar accompanied by a bouncer and Davis, an off-duty police officer employed as a security guard. While Flowers waited in the parking lot for his girlfriend, he and Davis talked. Officer Renfro, another off-duty Springfield police officer employed by the bar, without warning or provocation, grabbed Flowers and slammed him to the pavement face first, knocking out Flowers’ tooth. Renfro then placed Flowers under arrest. Flowers had not verbally or physically threatened the officers and was not showing any indication that he would resist arrest. The only conduct that Renfro claims justified slamming Flowers to the ground was that Flowers questioned the command to leave the bar and turned around to face Davis within one to two feet of him. Flowers disputes that he ever turned to face Davis.
Flowers sued the city, Renfro, and Davis under 42 U.S.C. 1983. The district court denied the defendants’ motions for summary judgment, which asserted that the officers did not violate Flowers’ civil rights and were entitled to qualified immunity. The Seventh Circuit dismissed an appeal for lack of jurisdiction because the district court held that there are genuine issues of disputed fact, material to Flowers’ claim against Renfro; the reasonableness of that use of force would inform a decision on qualified immunity.
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