Shelton v. Stevens, No. 18-3379 (8th Cir. 2020)
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Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force and seeking damages for injuries sustained during plaintiff's arrest. The district court denied the officer's motions for summary judgment.
The Eighth Circuit agreed with the district court that, on balance, the challenged use of force was unreasonable, but that the question is not beyond debate, and the right at issue was thus not clearly established. In this case, officers were attempting to arrest plaintiff for his role in a brutal beating, plaintiff fled from officers at high speed for several miles while armed with a handgun and ammunition, and a foot race ensued after the car chase where five officers pinned plaintiff. While the officers pinned plaintiff, plaintiff refused to surrender his hands and the officers reasonably believed that plaintiff's position posed a threat to officer safety, because at least one of his hands was unrestrained in an area of his body where weapons could be concealed. Therefore, the court held that it was objectively reasonable for officers to apply some amount of supplemental force in order to gain control of plaintiff's hands and to restrain him. However, the court held that the officer's use of force was unreasonable under the Fourth Amendment. The court stated that a stomp on the ankle with sufficient force to break it was excessive when the legitimate objective was to facilitate restraint of plaintiff's hands while he was pinned to the ground by several officers.
The court stated that a number of the relevant factors supported the use of force, so reasonableness was a matter of degree, and qualified immunity protects officers from the specter of lawsuits and damages liability for mistaken judgments in gray areas. Accordingly, the court reversed the denial of qualified immunity.
Court Description: [Colloton, Author, with Wollman and Benton, Circuit Judges] Civil case - Civil rights. In suit for excessive force during an arrest, the district court erred in denying the defendant officer's motion for summary judgment based on qualified immunity; while, on balance, the force used to secure plaintiff's arrest after he refused to exit his car, was seen sitting on a gun, fled from officers, led them on a high speed car chase and a foot chase and refused to surrender his hands once brought to the ground was unreasonable, the question is not beyond debate, and the right at issue was thus not clearly established; defendant's act of stomping on plaintiff's ankle and breaking it falls within the zone described sometimes as a hazy border between excessive and acceptable force; a number of relevant factors supported the use of force, so reasonableness was a matter of degree, and qualified immunity protects officers from the specter of lawsuits and damage liability for mistaken judgments in gray areas.
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