Background
Plaintiff Bradley Bolin, a pretrial detainee, sued multiple law enforcement officers and Benton County under Section nineteen eighty-three for excessive force and due process violations following his arrest and booking on April first, two thousand and twenty. The district court denied the officers’ motion for summary judgment based on qualified immunity, leading to this interlocutory appeal.
The court’s reasoning
The court held that for the Booking Lobby incident, the audio recording blatantly contradicted the district court’s finding of a factual dispute regarding resistance, as Bolin refused orders and invited the taser use. Consequently, the taser deployment was not objectively unreasonable. However, for the Booking Cell Three incident, the court found it clearly established that firing a pepper spray gun at a detainee with raised arms and no physical threat was unconstitutional. Similarly, the court affirmed that slamming a non-threatening detainee to the ground and tasing a non-violent detainee in Pod E-one oh three violated clearly established law.
The audio recording blatantly contradicts the district court’s conclusion that there was a genuine dispute of material fact regarding whether Bolin resisted deputies when he was on the ground.
Bolin v. Wilkins, No. 24-3491 (8th Cir. May 7, 2026)
What it means going forward
Deputy Loya is shielded from liability for the taser use in the Booking Lobby, while the other officers remain subject to trial for their use of pepper spray and physical force against Bolin.
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