Ames v. King County, No. 14-36035 (9th Cir. 2017)
Annotate this CasePlaintiff filed suit against King County and King County Sheriff's Deputies, under 42 U.S.C. 1983, alleging, inter alia, that Deputy Volpe violated her Fourth Amendment rights by arresting her without probable cause, conducting an unreasonable seizure, using excessive force during the arrest, and conducting an unlawful search of her truck. Deputies Volpe, Sawtelle, and Christian appealed the district court’s denial of qualified immunity on the excessive force and unlawful search claims. The court concluded that the deputies are entitled to qualified immunity in this case because the government's interests at stake - providing life-saving emergency medical care and to protect first responders and other motorists from potential harm - outweighed any intrusion on plaintiff's Fourth Amendment rights. The court thought that Deputy Volpe’s use of force in this case was reasonable in response to the totality of the circumstances. Furthermore, Deputies Sawtelle and Christian did not violate plaintiff's Fourth Amendment rights when they searched her truck in an attempt to find the medications plaintiff's son had ingested in his overdose. Accordingly, the court reversed and remanded for entry of dismissal.
Court Description: Civil Rights. The panel reversed the district court’s denial, on summary judgment, of qualified immunity to King County Sheriff’s Deputies in a 42 U.S.C. § 1983 action in which plaintiff alleged, among other things, that deputies violated her Fourth Amendment rights by using excessive force during an arrest and unlawfully searching her truck. The panel held that the deputies were entitled to qualified immunity because their actions were objectively reasonable in light of the urgent need to deliver life-saving care to an overdose victim, and to ensure the safety of everyone at the scene.
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