Background
Plaintiffs Mark Robinson and Jasmine Brown sued defendants Jordan Vance, Russell Mathis, and DeKalb County, Georgia, regarding the death of Marando Salmon. The plaintiffs alleged violations of the Fourth Amendment based on unlawful entry into Salmon’s home without a warrant and excessive force resulting in death. Defendant Russell Mathis filed a motion to dismiss based on qualified immunity, which the district court denied. Mathis appealed that ruling, while the plaintiffs moved to dismiss the appeal, arguing the court lacked jurisdiction.
The court’s reasoning
The court determined it had jurisdiction because Mathis’s challenge to the denial of qualified immunity presented an issue of law. Citing Behrens v. Pelletier and Ashcroft v. Iqbal, the court noted that denials of motions to dismiss or summary judgment on qualified immunity grounds are immediately appealable to the extent they turn on questions of law. The court further explained that while factual disputes may exist, the appeal does not present only factual issues, and appellate courts may address factual issues that are part of the core qualified immunity analysis.
What it means going forward
The denial of the motion to dismiss allows the appeal regarding the qualified immunity defense to proceed to the merits, enabling the appellate court to review whether the district court correctly applied the law to the facts.
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