Background
Nyra Miller-Fields, as personal representative of the estate of Ricky Cobb, II, sued two Minnesota state troopers under Section nineteen eighty-three of Title forty-two of the United States Code. Cobb was stopped for driving without headlights and was found to be wanted for a felony protective order violation. When troopers attempted to arrest him, Cobb shifted his vehicle into drive, causing the car to move forward with one officer partially inside. Trooper Londregan fired twice, killing Cobb. The district court granted the troopers’ motion to dismiss based on qualified immunity.
The court’s reasoning
The court reviewed the case de novo, accepting the complaint’s facts in the light most favorable to the plaintiff except where contradicted by video evidence. The court found the troopers had reasonable suspicion to extend the stop and probable cause to arrest Cobb for violating a protective order. Regarding the excessive force claim, the court determined that the law was not clearly established that using deadly force in this specific context violated the Fourth Amendment. The court noted that a moving vehicle can be a deadly weapon and that the troopers faced a high-pressure situation requiring split-second judgment.
Miller-Fields has not shown that Trooper Londregan violated a clearly established right if he did not issue a warning before shooting Cobb.
Miller-Fields v. Londregan, No. 24-3412 (8th Cir. July 7, 2026)
What it means going forward
The decision reinforces that qualified immunity protects officers who use force against suspects who use vehicles to resist arrest or endanger officers, even when the suspect is unarmed, provided the law was not clearly established that such specific conduct was unconstitutional.