Ransom v. Grisafe, No. 14-2204 (8th Cir. 2015)
Annotate this CaseRansom was driving home to Kansas City. His van began backfiring. He pulled over. Someone called 911 and reported that shots had been fired from or near a white van, though the caller did not report seeing flashes. Officers Phillips and Conaway arrived and pulled behind Ransom’s van, which had on its hazard lights. The van backfired; its driver’s-side door opened. Phillips yelled, “Get back in.” Ransom apparently did not hear and stepped out. The officers fired eight shots. Ransom did not notice that they had fired at him. The officers reported “shots fired.” Ransom stated “My van is backfiring.” Phillips stated, ““No, it’s not. Our window’s shot out” and ordered Ransom to walk toward the squad car. Ransom complied. The Officers requested back-up, thinking another person might be shooting from a ditch. Ransom was taken to police headquarters. When his interview ended, he accepted a ride. Officers pulled behind the van, began to exit, and heard a loud backfire that they thought was a gunshot. The officers believed that they were being “ambushed.” When Ransom did not follow a command to get back in his car, Phillips believed that Ransom was attempting suicide by cop and feared for his safety and for bystanders. The officers thought they heard more shots and fired at Ransom. An investigation determined Ransom’s van was backfiring; there was no suspect nearby. Ransom was again questioned. In his suit under 42 U.S.C. 1983, the court concluded that there were disputed issues and denied the officers’ motion for qualified immunity. The Eighth Circuit directed judgment in favor of the defendants, finding the officers’ conduct reasonable.
Court Description: Per Curiam - Before Riley, Chief Judge, and Colloton and Kelly, Circuit Judges] Civil case - Civil rights. In the case officers responded to a report of shots being fired from defendant's van and then misidentified backfires from his van as gun shots and fired at plaintiff and detained him. The district court erred in denying the two responding police officers' motion for summary judgment based on qualified immunity as any seizure of plaintiff through the use of deadly force was justified based on the facts conveyed to the officers, their own belief that shots had been fired at them and their belief that they were at risk of serious physical harm; officers also acted reasonably when they physically seized defendant and handcuffed him, again based on their reasonable belief that they were in danger of being shot; two other officers who responded and took plaintiff to a police station for questioning had probable cause to detain him and take him to the station for an interview; fifth officer did not detain defendant intentionally and was entitled to qualified immunity. Chief Judge Riley, concurring in an opinion which reiterates the need for district court judges to "carefully conduct a through qualified immunity analysis." Judge Kelly, concurring in part and dissenting in part.
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