Hanson v. Best, No. 17-3821 (8th Cir. 2019)
Annotate this CasePlaintiff filed a 42 U.S.C. 1983 action against police officers, in their individual capacities, alleging that the officers used excessive force and exhibited deliberate indifference to medical needs in an incident that led to the death of her son. The Eighth Circuit reversed the district court's denial of summary judgment based on qualified immunity to the officers and held that the officers' use of force did not violate clearly established law nor did their actions on the scene exhibit deliberate indifference to medical needs. In this case, there was insufficient evidence that a need for medical treatment was so obvious that law enforcement exhibited deliberate indifference by taking the son to jail. Furthermore, the officers were not deliberately indifferent when they called paramedics to assist him.
Court Description: Shepherd, Author, with Colloton and Stras, Circuit Judges] Civil case - Civil rights. Under the applicable Supreme Court and Eighth Circuit precedents there is not a clearly established right against the use of prone restraints for a suspect who has been resisting police, and the police officers were entitled to qualified immunity on plaintiff's claim that they used excessive force on her decedent; where medical professionals at the scene never even suggested that emergency medical treatment was needed, there is insufficient evidence that decedent's need for medical treatment was so obvious that the police officers exhibited deliberate indifference by taking him to jail; further, by calling the paramedics to the scene, the officers did not deliberately disregard the man's medical needs. The district court erred in denying the officers' motion for summary judgment based on qualified immunity, and the matter is remanded for further proceedings.
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