RICHARD P. HARROLD Plaintiff – v. LEWIS J. HAGEN
The Fourth Circuit vacated the district court's grant of qualified immunity, holding that a non-threatening, unarmed, and passively resisting suspect possesses a clearly established Fourth Amendment right to be free from unnecessary K-9 deployment. The court concluded that Officer Hagen's use of force was disproportionate under existing precedent, requiring the case to proceed to trial rather than being dismissed at this procedural stage.