Background
Two brothers, William and Michael Martin, sued Lieutenant Mauricio Duran and Officer Bridget Doyle for stopping and arresting them on January tenth, two thousand and eighteen. The officers moved for summary judgment, and the district court denied qualified immunity to Lieutenant Duran regarding the stop and to Officer Doyle regarding a second taser deployment on William.
The court’s reasoning
The court held that Lieutenant Duran was entitled to qualified immunity because the Martins failed to show that clearly established law placed the question of the stop beyond debate. The court found that the district court relied on a case involving permissible police behavior rather than a violation, and no other precedent materially similar to the facts existed. Regarding Officer Doyle, the court applied the Supreme Court’s Barnes decision, which requires considering all relevant circumstances leading up to the use of force. The court found that because William was screaming in pain, lying on his back with arms extended, and no longer a threat, the second taser deployment was objectively unreasonable under the Fourth Amendment.
What it means going forward
Police officers may be shielded from liability for stops based on arguable reasonable suspicion even if the underlying facts are disputed, but they remain liable for using force on individuals who are immobilized and no longer pose a threat.