Case Explained: Nyra Jean Miller-Fields v. Ryan Londregan Brett Seide

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-07

The eighth-circuit affirmed the district court’s grant of the troopers’ motion to dismiss based on qualified immunity in a civil rights action brought under 42 U.S.C. § 1983 alleging unreasonable seizure and excessive force in violation of the Fourth and Fourteenth Amendments. The court held that the troopers did not violate any constitutional right because their conduct was objectively reasonable under the circumstances, and no clearly established law would have made it apparent to a reasonable officer that such conduct was unlawful. Regarding the claim of an unreasonable seizure, the court applied the standard that officers need only reasonable suspicion to extend a traffic stop and probable cause to make a warrantless arrest. The court found that the troopers had reasonable suspicion to extend the stop based on Cobb’s active felony protective order violation and possessed probable cause to arrest him after receiving instructions from Ramsey County authorities. Regarding the excessive force claim, specifically the use of deadly force when Cobb shifted his vehicle into drive with a trooper partially inside, the court applied the qualified immunity standard requiring that the right be “clearly established” with a high degree of specificity. The court determined that while *Tennessee v. Garner* sets general principles, it does not clearly establish that shooting a suspect who moves a car forward while an officer is reaching inside constitutes excessive force. Similarly, the court found that the use of force to ram the vehicle was objectively reasonable because Cobb had accelerated onto a busy highway, posing an immediate threat to officers and the public, distinguishing the situation from cases involving subdued suspects in custody. The practical consequence is that the district court’s dismissal of the case against Troopers Londregan and Seide stands, ending the litigation on these claims without a trial on the merits.

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