Background
Officer Jon Grubbs chased Jerry Blasingame, a homeless man, who ran down a steep embankment. Officer Grubbs tased Mr. Blasingame in the back without warning, causing him to fall and suffer severe injuries including quadriplegia. A jury awarded Mr. Blasingame’s estate one hundred million dollars, but the district court later reduced punitive damages and granted judgment as a matter of law to the City of Atlanta.
The court’s reasoning
The court held that tasing a suspect from a height of thirty feet with a highway below is equivalent to deadly force. The officer lacked probable cause to believe the suspect posed a threat of serious physical harm. The court found the law was clearly established by Tennessee versus Garner and Bradley versus City of Atlanta. Regarding municipal liability, the court found no evidence that the City’s failure to enforce body-worn camera policies was the moving force behind the violation. The court affirmed the reduction of punitive damages, noting the award was excessive relative to the harm and the officer’s conduct.
We conclude that there was sufficient evidence from which a reasonable jury could find a Fourth Amendment violation.
Edwards v. Grubbs, 169 F.4th 1261 (11th Cir. 2026)
What it means going forward
Police officers are on notice that using tasers on fleeing suspects from elevated positions where serious injury is likely constitutes excessive force. Municipalities cannot be held liable under Section one thousand nine hundred and eighty-three solely for failing to enforce recording policies without a direct causal link to the constitutional violation.