K.W.P. v. Kansas City Public Schools, No. 17-3602 (8th Cir. 2019)Annotate this Case
Plaintiff, a 7 year old elementary school student, filed a 42 U.S.C. 1983 suit against KCPS, Officer Craddock, and Principal Wallace for violations of his rights under the Fourth and Fourteenth Amendments. Plaintiff's claims arose when he was handcuffed in school after an outburst in the classroom against a classmate that was incessantly teasing him. The district court determined that disputed material facts precluded dismissal of the student's claim against the officer and principal, and denied summary judgment to KCPS.
The Eighth Circuit held that neither the officer nor the principal violated the student's constitutional rights, and they were entitled to qualified immunity on plaintiff's claim of unreasonable seizure and excessive force. In this case, a reasonable officer could conclude that, based on the student's recent resistance, keeping him in handcuffs for 15 minutes until a parent arrived was a reasonable course of action and was necessary to prevent him from trying to leave and posing harm to himself. Furthermore, the principal's failure to intervene and have the officer remove the handcuffs was reasonable in light of her previous experience with the student. Even if the reasonableness of the officer and the principal's actions were questionable, the student could not show that a reasonable official would have been on notice that their conduct violated a clearly established right. The court also held that, because there was no violation of the student's constitutional rights, the student's municipal liability claims failed. Therefore, the court reversed the district court's denial of summary judgment for the officer, principal, and KCPS, remanding for entry of summary judgment in their favor on the student's claims.