McReynolds v. Schmidli, No. 19-3772 (8th Cir. 2021)
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After plaintiff sustained significant injuries during the course of an arrest on domestic violence and related charges, he filed suit against the arresting officers, city officials, and the City of Independence, alleging violations of his constitutional rights. The district court granted summary judgment to the defendants on all claims.
The Eighth Circuit concluded that the district court erred in granting qualified immunity to Defendant Schmidli; plaintiff has shown a violation of the constitutional right to be free from excessive force by law enforcement; and a reasonable officer would have had fair warning that, at the time, he could not violently takedown a person who was not threatening anyone, not actively resisting arrest, and not attempting to flee. However, the court concluded that Defendant Gentile was entitled to qualified immunity because there was insufficient evidence that he used excessive force or significantly contributed to the driving force that caused the injury.
The court also concluded that the defendant officers are entitled to summary judgment on the substantive due process claim where plaintiff failed to provide any evidence that any inaccuracy in the officers' reports was fabricated in order to frame him. Furthermore, there is no reasonable inference drawn from plaintiff's version of the facts that would allow a finder of fact to conclude that Schmidli and Gentile deliberately lied with the intention of framing him. Finally, the City was entitled to summary judgment on plaintiff's Monell claim where plaintiff failed to establish the City had an unofficial custom authorizing officers to use excessive force.
Court Description: [Erickson, Author, with Smith, Chief Judge, and Kelly, Circuit Judge] Civil case - Civil rights. In the context of excessive force claims, the court has previously explained that use of significant force against a suspect who is compliant and neither a threat nor a flight risk is not objectively reasonable, and on these facts, plaintiff showed violation of his constitutional right to be free from excessive force by law enforcement officers; additionally, a reasonable officer would have had fair warning on the date of the incident that he could not violently takedown a person who was not threatening anyone, not actively resisting arrest, and not attempting to flee, thus making plaintiff's right clearly established; as a result, the district court erred in granting qualified immunity to defendant Schmidli; officer Gentile was entitled to qualified immunity as there was insufficient evidence that he used excessive force or significantly contributed to the driving force that caused the injury; the district court properly granted summary judgment on plaintiff's due process false-evidence claims as there was not sufficient evidence to find the officers deliberately fabricated their reports or deliberately lied to frame plaintiff; plaintiff failed to establish the City had an unofficial custom authorizing officers to use excessive force, and the City was entitled to summary judgment on plaintiff's Monell claim.
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