Torres v. Coats, No. 21-1918 (8th Cir. 2022)
Annotate this CaseIsaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings.
Court Description: [Shepherd, Author, with Benton and Stras, Circuit Judges] Civil case - Civil rights. Hammett was killed by St. Louis Police officers during the execution of a search warrant at his grandfather's home; his mother and grandmother brought this Section 1983 excessive force and unlawful seizure and state law wrongful death action against the officers, the City and the Department; the City and officers moved for summary judgment based on qualified immunity and sovereign and official immunity, and the district court denied, in the main, their motions. Defendants appeal. The court lacked jurisdiction to consider the denial of defendants' motion for summary judgment on plaintiffs' excessive force claims because there were genuine issues of material fact concerning whether the officers used excessive force, including whether the decedent was armed and whether he posed an imminent threat; plaintiff did not show defendants Boyce or Lacy were personally involved in the alleged use of excessive force, and they were entitled to qualified immunity on plaintiffs' Fourth Amendment excessive force claims; the issue of whether plaintiffs' decedent had a clearly established right to be from the use of deadly force in this situation is dependent on the disputed issues as to whether he was armed, and the district court did not err in denying the remaining officers' motion for summary judgment; with respect to plaintiff Dennis Lopez's claim that he was subjected to excessive force and unlawful seizure, there was no application of physical force or acquiescence to a show of authority, so Dennis was not seized for Fourth Amendment purposes, and the officers were entitled to qualified immunity on his excessive force and unlawful seizure claims; the defendants were entitled to qualified immunity on plaintiffs' Section 1985 conspiracy claims as the City could not conspire with itself through the defendant officers acting within the scope of their employment; it is not clearly established that the intracorporate conspiracy doctrine does not apply to Section 1983 conspiracy claims, and the district court's denial of qualified immunity on the Section 1983 conspiracy claims is reversed; with respect to defendants' claims they were entitled to official immunity on plaintiffs' state law claims, the court lacked jurisdiction to consider the matter because the question presented was one of the sufficiency of the evidence rather than an issue of law; on this record, the district court erred in concluding that disputed issues of material fact existed as to whether the City was self-insured, and the denial of the City's claim of sovereign immunity is reversed.
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