Christopher Lankford v. City of Plumerville, Arkansas, No. 21-1639 (8th Cir. 2022)
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Plaintiff was severely injured when his motorcycle crashed into a police SUV while he was fleeing from police. Plaintiff sued the City of Plumerville, Arkansas (the “City”), and its police officer for use of excessive force. The district court granted summary judgment to the City and the officer.
The Eighth Circuit affirmed. The court explained that claims against local police for excessive force during a seizure are analyzed under the Fourth Amendment’s reasonableness standard. The court wrote it consistently held deadly force is not unreasonable where an officer has probable cause to believe that the suspect poses a threat of serious physical harm, either to the officer or others. The court held that the undisputed evidence reveals that the police officer had probable cause to believe Plaintiff’s flight threatened the lives of innocent bystanders as well as police. Accordingly, the court held that the officer’s actions were reasonable. Moreover, the court found that the severity of the officer’s use of force was mitigated by the opportunity the officer gave Plaintiff to avoid the collision.
Finally, the court explained that it assesses the reasonableness of deadly force for Fourth Amendment purposes from the seizing officer’s perspective at the time of the incident. The court found that based on the police officer’s knowledge at the time when he was forced to make a quick judgment, the court concluded the Fourth Amendment’s reasonableness standard gave the officer more leeway than would have the Morrilton police officers.
Court Description: [Grasz, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Civil case - Civil rights. Plaintiff was injured when his motorcycle crashed into a police SUV while he was fleeing from police, and he brought this action alleging excessive force. The defendant police officer had probable cause to believe that plaintiff's high speed flight threatened the lives of innocent bystanders as well as police, and his action in partially blocking the highway with his police vehicle was reasonable.
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