Steed v. Missouri State Highway Patrol, No. 20-2183 (8th Cir. 2021)
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After Jerome Goode led police on a twenty-five-mile car chase, the chase ended in his death and the deaths of passengers Lavoy Steed and Leon Haywood. Steed's next friend filed a 42 U.S.C. 1983 action against Missouri State Troopers Fowler and Ashby, alleging that the traffic stop that precipitated the chase and an attempt to halt Goode's vehicle with spike strips were unconstitutional seizures in violation of the Fourth Amendment.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the troopers, concluding that Trooper Fowler had probable cause to stop the vehicle where dashcam footage shows the vehicle going close to ninety miles per hour. Even assuming that the trooper misinterpreted the speed reading, he would still be entitled to qualified immunity because he had at least arguable probable cause to believe the vehicle was speeding. The court also concluded that the record clearly establishes that the troopers did not apply physical force by trying to use the spike strips, and thus there was no seizure.
Court Description: [Kobes, Author, with Kelly and Grasz, Circuit Judges] Civil case - Civil rights. A state trooper had probable cause to stop the vehicle in which plaintiff's decedent was riding based on the record which showed the SUV was speeding at close to 90 mph; a second state trooper did not violate the plaintiff's decedent rights by setting a spike strip as the record clearly showed the vehicle evaded the strips and continued to drive on; as a result the officer did not apply physical force by trying to use the spike strips, so there was no seizure.
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