Blazek v. Santiago, No. 12-3785 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against Officers Santiago and Roth, the City, and the State, alleging constitutional violations under 42 U.S.C. 1983 and state-law violations when the officers unlawfully seized him and used excessive force. On appeal, the officers challenged the district court's denial of their motion for summary judgment. The court agreed with the district court that a reasonable jury could find a violation of the Fourth Amendment when the officers "jerked" plaintiff up by the arms, when he was already under control and handcuffed, with sufficient force to cause serious injury to his shoulder area. Further, the law was sufficiently developed to show that such a violation - allegedly involving unnecessary violence against a handcuffed and compliant detainee - would contravene clearly established law at the time. Accordingly, the court affirmed the judgment of the district court. The court lacked jurisdiction to resolve plaintiff's state-law claims against Officer Roth and the City.
Court Description: Civil case - Civil rights. In light of plaintiff's behavior, it was reasonable for the defendant officers to detain and handcuff plaintiff while they conducted a probation check on his roommate; however, the district court did not err in denying the officers' motion for summary judgment based on qualified immunity on plaintiff's claim that the officers used excessive force when they jerked him from the floor to his bed; at that point in the encounter, plaintiff was handcuffed and under control and a reasonable jury could find, if plaintiff can prove that the the officers "gratuitously jerked him" using enough force to cause significant injury, that the force used was a violation of plaintiff's Fourth Amendment rights; resolution of this qualified immunity issue does not resolve plaintiff's state-law claims against the defendants and the court does not have jurisdiction to consider defendant Roth's interlocutory appeal on those issues. Judge Gruender, concurring in part and dissenting in part.
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