Moore-Jones v. Quick, No. 18-1045 (8th Cir. 2018)Annotate this Case
Moore-Jones passed Arkansas State Trooper Quick’s marked police car. Quick checked and found her registration was expired and began a traffic stop, which was recorded on his dash-cam. Quick pulled behind Moore-Jones, activating his emergency lights, spotlight, and sirens at 8:23 p.m. She decelerated and pulled onto the shoulder, which was narrow and unlit. She returned to the road, accelerating to 35-38 MPH, her speed for the rest of the pursuit. The posted speed limit was 55 MPH. At 8:24, she continued past the last exit before the nearest city. After the exit, Quick began a Precision Immobilization Technique (PIT) maneuver, striking Moore-Jones's right-rear fender with his left-front bumper, causing her car to spin into a ditch, hitting a cement culvert. Moore-Jones and her child and were treated and released at a hospital. She was cited for expired tags and failure to yield to an emergency vehicle, both misdemeanors. She sued Quick for excessive force and assault and battery. The Eighth Circuit held that Quick is entitled to qualified immunity. The right to be free from a PIT maneuver in these circumstances was not sufficiently definite. From a reasonable officer’s perspective, Moore-Jones refused to comply with commands to pull over. At the time, Quick was justified in using some force to secure compliance.