Clark v. Clark, No. 18-1324 (8th Cir. 2019)Annotate this Case
Plaintiff filed suit against a police deputy, alleging that the deputy violated plaintiff's rights under the First Amendment, Fourth Amendment, and the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the deputy based on qualified immunity. The court held that the initial encounter at the rest stop presented no colorable claim that plaintiff's Fourth Amendment rights were violated where an objectively reasonable officer would have articulable suspicion to conduct a Terry stop; the seizure of plaintiff on the highway exit ramp did not run afoul of the Fourth Amendment and was reasonably related in scope to the circumstances which justified the interference; pointing a firearm at plaintiff for a few seconds while removing him from his vehicle did not constitute excessive force, and did not violate the Fourth Amendment; and, in light of the deputy's legitimate motive to investigate, plaintiff failed to draw the requisite causal connection to state a First Amendment retaliation claim.