Shultz v. Buchanan, No. 15-1854 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983 and state law, alleging that Officer Buchanan violated his rights under the Fourth Amendment by entering his home unlawfully and by using excessive force against him during an arrest. Plaintiff also alleged that the City was liable for maintaining an unconstitutional policy governing its officers. The district court concluded that Buchanan was entitled to qualified immunity on the federal claims, plaintiff failed to present any evidence supporting his claim against the City, and the state law claims had no merit. The court concluded that the scenario confronting Buchanan was close enough to the line of a valid entry that he is entitled to qualified immunity. In this case, when the officer arrived at the residence, plaintiff had been drinking, he was upset and knocked over a chair as he rose to approach Buchanan, and Buchanan heard yelling from both an adult and children. Under these circumstances, a reasonable officer in Buchanan’s position could have concluded that there were reasonable grounds to believe that a person in the residence was in need of immediate aid. Therefore, the entry did not violate plaintiff's rights. The court also concluded that Buchanan is entitled to qualified immunity on plaintiff's excessive force claim where it was not clearly established at the time that an officer violated the rights of an arrestee by applying force that caused only de minimis injury. Finally, the district court properly dismissed plaintiff's claim that the City maintained an unconstitutional policy where he failed to present evidence that the City’s policy directed Buchanan to act unconstitutionally or otherwise caused a deprivation of plaintiff’s rights. Accordingly, the court affirmed the judgment, including the dismissal of the state law claims.
Court Description: Colloton, Author, with Wollman and Melloy, Circuit Judges] Civil case - Civil rights. The defendant police officer entered plaintiff's home without a warrant to provide emergency assistance or protect a person from injury and the officer was entitled to qualified immunity on plaintiff's claim that the entry violated his civil rights; on plaintiff's claim that defendant used excessive force to secure plaintiff's arrest, it was not clear on the date of the incident that an officer violated the rights of an arestee by applying force that caused only de minimus injury, and the officer was entitled to qualified immunity on the claim; City was entitled to dismissal of plaintiff's claim the City maintained an unconstitutional policy, as plaintiff failed to present evidence that the City's policy directed the officer to act unconstitutionally or otherwise caused a deprivation of plaintiff's rights.
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