Tinsley v. Town of Framingham
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The Supreme Judicial Court vacated the judgment of the trial court granting summary judgment on several claims against police officers personally, holding that there was a genuine issue of material fact whether the police officers used excessive force against Appellant after he was removed from his vehicle.
Plaintiff, a black man, was stopped by two police officers. The stop escalated into a physical altercation during which five police officers forcibly removed Plaintiff from the vehicle and wrestled him to the ground. Plaintiff was convicted of several offenses stemming from the incident. While the criminal case was pending, Plaintiff filed a civil action alleging that the officers committed several torts and violated his civil rights. The trial court granted summary judgment for Defendants on the civil action. The Supreme Judicial Court vacated the judgment in part, holding (1) Plaintiff's civil action may only proceed where it is based on facts beyond those that were necessary to sustain Plaintiff's prior criminal conviction and where Plaintiff demonstrates that his claims would not necessarily challenge the validity of his prior criminal conviction; and (2) this conclusion does not bar the claims that Plaintiff based on events that occurred after the police officers forcibly removed him from his vehicle.
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