Background
Sage Antony Stellar, formerly known as Anthony Charles Hall, appealed the district court’s grant of summary judgment in his favor on his excessive force claim against the Mohave County Sheriff’s Department and other defendants. Stellar argued that the district court relied on fraudulent evidence, specifically Axon bodycam footage of his arrest on January eighth, two thousand and twenty-one.
The court’s reasoning
The panel first addressed the claim of fraud on the court. The court noted that while federal courts have the inherent power to vacate judgments for fraud, such power is exercised with restraint and only when fraud is established by clear and convincing evidence. Stellar asserted he was not the person in the footage because the individual depicted lacked his distinctive tiger-stripe leg tattoo. However, the court found Stellar’s evidence insufficient because he provided no corroboration for the dates of his photos, it was unclear if the photos showed a tattoo or a drawing, the footage aligned with his original complaint, and his theory that defendants fabricated the video was implausible. The court then found no plain error in the summary judgment, noting that Deputy Rider used a reasonable amount of force to subdue Stellar, who was suspected of stabbing his roommate and had engaged in uncooperative and antagonistic behavior.
What it means going forward
The decision reinforces the high evidentiary burden required to prove fraud on the court and upholds summary judgment where the plaintiff’s challenge to video evidence is unsupported by clear and convincing proof.