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Assault and Battery: Physical

     Sheriff's deputies who arrested a man for "resisting, evading or obstructing an officer" were not entitled to qualified immunity in his lawsuit claiming that they used excessive force in doing so. The suspected crime was a misdemeanor, and not a "severe" crime, and the deputies themselves did not contest an assessment that a jury could conclude that he posed no immediate danger to their safety. The plaintiff asserted that he did not try to evade the deputies or resist their efforts to arrest him, but that, despite this, they gang-tackled him, applying force sufficient to tear his knee ligaments. The deputies also ultimately conceded that attempted flight by the arrestee had been no more than possible, and was perhaps "unlikely." It was clearly established, the court held, that the "gratuitous" use of force against a non-resisting arrestee would violate the Fourth Amendment. Herrera v. Bernalillo County Board of Commissioners, #09-2042, 2010 U.S. App. Lexis 1246 (Unpub. 10th Cir.).

Assault and Battery: Stun Guns/Tasers

     An officer, concerned for a bicycle rider's safety, rolled down the window of his vehicle and suggested that the man get off a busy street near the airport. The bicycle rider pulled over, and the officer also stopped and exited his vehicle, allegedly telling the bike rider to "get up on the curb or you will be tasered or maced." After a discussion, the bike rider started riding off, and the officer allegedly grabbed him and threw him to the ground. A second officer on the scene then used a Taser on the man after a struggle ensued. It was disputed whether he was resisting the officers. The bicycle rider claimed that the resulting pain was "excruciating," and that it completely incapacitated him, causing him to collapse to the ground and suffer additional scrapes and bruises. The bicycle rider filed an excessive force lawsuit. The court held that a reasonable jury could find that excessive force was used, as the bicycle rider had not committed a serious or violent crime, and that there was a genuine issue of fact as to whether he posed an immediate threat to the officers when the Taser was used on him. "Even if a Taser does not require hospitalization or cause quantifiable injuries, it does cause extreme pain, and such pain may support a claim for excessive force." Orsak v. Metropolitan Airports Cmsn. Police Dept., #08-5274, 2009 WL 5030776, 2009 U.S. Dist. Lexis 116382 (D. Minn.).

Attorneys' Fees

****Editor's Case Alert****

     A California Highway Patrol officer shot and killed a man during a struggle while on duty. The decedent had a long history of schizophrenia, accompanied by drug and alcohol abuse. He was unemployed and survived on Social Security benefits and support from his mother. A lawsuit by the man's estate and by his mother resulted in jury awards of $1 each on a federal civil rights excessive force claim and a state law wrongful death claim, based in part on evidence that appeared to refute the officer's assertion that, at the time of the shooting, the decedent had been swinging a flashlight at him. Subsequently, the trial court awarded the plaintiffs $136,687.35 in attorneys' fees. A federal appeals court upheld the attorneys' fee award, based on findings that the legality of the use of deadly force under these circumstances was an important legal issue, even if substantial damages were not awarded, and that the award of attorneys' fees would be likely to deter the officer from similar future unconstitutional conduct. Mahach-Watkins v. Depee, #08-15694, 593 F.3d 1054 (9th Cir. 2010).

Domestic Violence and Child Abuse

     Parents and students claimed that a Nevada state child protection official improperly removed the students from a school during an abuse investigation. The action was taken after the official had compiled a "significant amount" of evidence of sexual activity allegedly taking place at the school involving staff members and students, as well as poor living conditions, inadequate medical care, the lack of supervision, and the possibility that two employees had criminal records. The official, therefore, could have reasonably concluded that the removal of the students was justified by a concern for their safety and did not violate the Fourth Amendment. The actions also did not violate the parents' rights to family integrity under the Fourteenth Amendment, as the failure to contact them before removing the students did not violate clearly established law. Barragan v. Landry, #08-16790, 2010 U.S. App. Lexis 483 (Unpub. 9th Cir.).

DNA

     A man was convicted of a murder and jailed for ten years. Ultimately, he was exonerated based on post-trial DNA testing carried out by the district attorneys' office. He sued, contending that his rights were violated by a 72-day delay in informing him or his lawyer of the exculpatory results. A federal appeals court ruled that prosecutors were entitled to absolute immunity from liability because their actions were integrally connected to their role as advocates for the state in post-conviction proceedings. An order denying the defendant county's motion to dismiss was not immediately appealable. Warney v. Monroe County, #08-0947, 2009 U.S. App. Lexis 24914 (2nd Cir.).

False Arrest/Imprisonment: No Warrant

     A police officer was not entitled to qualified immunity on claims that he manipulated a photo lineup to try to produce a false identification of the plaintiff by a rape victim. The officer allegedly took photos of the plaintiff for use in a photo lineup, repeatedly altering the light settings on the camera with each picture in an effort to make the photograph better match the “dark tan” skin tone of the suspect in the police sketch of the suspect sought. While the arrestee was convicted of the crime, he was later exonerated by DNA evidence. A knowing effort to obtain a false identification of a suspect by fabricating evidence or otherwise acting improperly to influence a witness's identification is a violation of due process, and any reasonable officer would have known that acting in this manner was a violation of constitutional rights. The officer allegedly acted in this manner in anger over the fact that the plaintiff had refused to cooperate in his investigation of unrelated burglaries. Good v. Curtis, #09-10341, 2010 U.S. App. Lexis 3207 (5th Cir.).

     A man protesting outside a cultural center was informed by the president of the center's board of directors that he could not bring his protest sign into the building. When the protestor refused to leave the property, a deputy sheriff arrested him for trespass after first giving him a warning to leave. The deputy was entitled to qualified immunity, as it was reasonable for him to believe that the president was authorized to request the protestor's removal, and he had at least arguable probable cause for the arrest. Additionally, the officer could reasonably believe that ordering the man to leave the property was not a violation of his First Amendment rights. Moran v. Cameron, #09-11074, 2010 U.S. App. Lexis 1459 (Unpub. 11th Cir.).

False Arrest/Imprisonment: Unlawful Detention

     A married couple claimed that police officers acted unreasonably in stopping the family's vehicle and subjecting the husband to a prolonged investigatory detention based on an observation of the husband at a bank. Aside from being African-American, the husband did not look like the robbery suspect sought, since he was roughly twice the size of the suspect, and would not have been described as "muscular," even dressed in baggy clothes. Additionally, his conduct at the bank did not even remotely match the bank robber's method of operation, as the whole family, including two children, went to a drive-up window, parked, and then the husband, paycheck in hand, tried the front door, which was locked. The husband identified himself to the police as a pastor, but they allegedly did nothing to verify his identity. Under these circumstances, a 40-minute detention would be unreasonable, the appeals court stated, upholding a denial of summary judgment for the officers. Hopkins v. Vaughn, #08-2727, 2010 U.S. App. Lexis 2121 (Unpub. 3rd Cir.).

     An officer was entitled to qualified immunity for briefly detaining the plaintiff, a university student, since he had reasonable suspicion that he was a minor in unlawful possession of alcohol, observing him in a group, several of whom had beers in their hands as they walked across a square. He demanded the plaintiff's identification, checked the validity of his driver's license, and checked whether there were any outstanding warrants. The officer was not required to take the plaintiff's word that he was 21, and his initial refusal to hand over his license justified a suspicion that perhaps it was a phony, or there were outstanding warrants for the plaintiff's arrest. Klaucke v. Daly, #09-1222, 2010 U.S. App. Lexis 2633 (1st Cir.).

Firearms Related: Intentional Use

     Officers sent to a woman's home encountered her son, who came from the kitchen with a knife in one hand and a cigarette in the other. An officer shot and killed him. Summary judgment for the officer in an excessive force lawsuit was improper, since it was disputed whether or not the decedent had posed an immediate threat to the officer at the time of the shooting. The court also rejected a claim for liability against the officer's supervisor, as no connection was shown between any failure to supervise and the shooting. Reyes v. Bridgwater, #09-10076, 2010 U.S. App. Lexis 1502 (Unpub. 5th Cir.). In a related decision, the appeals court upheld summary judgment for the defendant city, as the plaintiffs failed to identify any municipal policy or custom linked to the shooting. The plaintiffs also failed to produce evidence that the chief of police was an official policymaker for the city. Reyes v. City of Plainview, #09-10412, .2010 U.S. App. Lexis 1681 (Unpub. 5th Cir.).

     A police officer was not entitled to qualified immunity in an excessive force lawsuit filed by a suspect who was permanently injured during a chase. Even if it were assumed that the initial use of deadly force was justified, the officer's alleged firing of an additional 10 to 12 shots while the plaintiff was unarmed on the ground and incapacitated, if true, was unjustified. The right not to be subject to further use of deadly force under such circumstances was clearly established. Jean-Baptist v. Gutierrez, #07-21728, 2010 U.S. Dist. Lexis 2498 (S.D. Fla.).

     A man shot and injured by two officers while fleeing from an armed robbery of a store claimed that one of the officers began shooting immediately after directing him to freeze, and that he was not then holding his gun in his hand. The officer, on the other hand, stated that the suspect had his gun in his hand, and ignored instructions to stop, turning towards the officers in a manner that made him believe that he was going to shoot. Based on these disputed facts, this officer was not entitled to summary judgment. Dismissal of claims against the second officer, however, was justified, based on insufficient service of process. Mack v. Dillon, #09-1295, 2010 U.S. App. Lexis 2746 (8th Cir.).

     A police officer responding to reports of gunfire in the area on New Year's Eve shot and injured a woman as she stood in the doorway of her home. He stated that he believed that she was firing at him, but she turned out to be unarmed. Accepting the plaintiff's version of the facts as true for purposes of appeal, the court upheld the denial of qualified immunity to the officer. A jury should resolve the factual dispute, and, depending on that determination, it still might be possible that the officer could be entitled to qualified immunity, if he reasonably, although mistakenly, believed that she was firing at him. Jefferson v. Lewis, #08-2116, 2010 U.S. App. Lexis 2348 (6th Cir.).

First Amendment

     A number of artists claimed that a city ordinance that barred them from selling reproduced prints of their work in a city square violated their First Amendment rights. The court found that the city had a legitimate interest in maintaining the "tout ensemble" (general effect) of the artists' colony at the city square, which would be adversely impacted if prints were allowed to be sold in the area. The ordinance was also narrowly tailored, only covering prints reproduced by mechanical or duplicative means. There were adequate alternative avenues for the artists to attempt to reach their audience. Sarre v. New Orleans, Civil Action #05-910, 2009 U.S. Dist. Lexis 122277 (E.D. La.).

Interrogation

     A husband and father was shot and killed after his 12-year-old daughter went to get a gun for him. Police suspected that he might have been murdered by his family members. The wife and daughter claimed that they were improperly detained in a police mobile unit for one-and-a-half to two hours when officers, actually engaged in installing a surreptitious listening device in their home pursuant to a warrant, falsely told them that there was a hostage situation involving a gun in the area so that they could not return to their home. The daughter, who was subsequently arrested, claimed that officers interrogated her without advising her of her right to have her attorney or mother present, and denied her access to her attorney or mother. She disputed the officers' claim that she had waived her rights. Denying motions by the officers for qualified immunity or judgment as a matter of law, the court instructed the jury on both unlawful detention and unlawful interrogation claims, The jury was also instructed on qualified immunity. The jury, answering special interrogatories, found that the officers' had not violated the plaintiffs' Fourth Amendment rights through unlawful detention, and that they did not engage in conduct that "shocks the conscience" in violation of due process in their interrogation of the daughter. While the plaintiffs argued that the trial judge acted erroneously in submitting the instruction on qualified immunity to the jury, the appeals court ruled that, even if this were the case, it would have been harmless, in light of the jury's answers to special interrogatories indicating a "total defense verdict" on all issues, including whether the officers engaged in unlawful detention or improper interrogation. Gonzales v. Duran, #08-2184 590 F.3d 855 (10th Cir. 2009).

Malicious Prosecution

    An arrestee sued Drug Enforcement Administration (DEA) agents, claiming that they violated his rights by subjecting him to arrest and prosecution without probable cause. The arrest took place after the agents were informed that a police officer had allegedly been selling large quantities of drugs, that a second officer had been supplying him with heroin, and that the plaintiff, who was also a police officer, had been in contact with both of them. When a meeting took place at a restaurant between an undercover agent and the two officers believed to be involved in the drug transactions, the plaintiff was also present, sitting at a nearby table. An agent subsequently testified at a grand jury proceeding that the plaintiff had been present as a bodyguard, leading to his indictment and arrest on charges for which he was later acquitted. The court ruled that the agents were entitled to qualified immunity, since a reasonable officer, confronting these facts, could have believed that the plaintiff was, in fact, involved in the drug trafficking and present as a bodyguard. Martinez-Rodriguez v. Guevara, #08-10862, 010 U.S. App. Lexis 4178 (1st Cir.).

Positional, Restraint and Compressional Asphyxia

     Deputies arrested a woman who responded to handcuffing by attacking one of them, forcing him to the ground, seizing his flashlight, and pummeling him about the head and shoulders. When she continued to resist efforts to place her in the deputies' vehicle, they placed her in four-point restraints, linking leg restraints to handcuffs with an additional set of handcuffs. She allegedly rode facedown in the back of the car on the way to the jail, became quiet, and may have stopped breathing. At the jail, she was unresponsive and without a pulse, and attempts to revive her failed. An autopsy diagnosed fatal hypothermia with the exact cause of death uncertain. The woman was obese and hypertensive, but neither drugs nor excessive alcohol were in her system. A federal appeals court rejected the argument that the deputies used excessive force to subdue the woman, and stated that it assumed the cause of death was positional asphyxia. The court found that the plaintiff failed to show that the use of the restraints was unnecessary, excessively disproportional to the resistance they faced, or objectively unreasonable in terms of its perils to the arrestee, who exhibited none of the additional contributing or associated factors that cast doubt on the propriety of such restraints in some cases, such as evidence of drug abuse or drug-induced psychosis. The appeals court also rejected a claim that the deputies acted with deliberate indifference, failing to adequately monitor the arrestee on the way to the jail. Hill v. Carroll County, 587 F.3d 230 (5th Cir. 2009).

Property

     A homeowner changed the locks on her marital home while undergoing a divorce. Her husband, accompanied by police officers, came to the home to get some of his property. The homeowner was ordered by the officers to open the door, and they remained on the scene for several hours while the husband removed furniture and other items. When the divorce was finalized, the wife was awarded most of the property removed. She sued the city and the officers, alleging a denial of due process and gender discrimination. Rejecting these claims, a federal appeals court found that the officers had properly informed the plaintiff that her husband had a right to enter his own home and remove property, so long as no breach of the peace occurred. There was also no evidence that the plaintiff was mistreated based on her sex, and she herself testified that she did not know the reason for the officers' actions. Johnson v. Wyant, #J09-12662, 2010 U.S. App. Lexis 1758 (Unpub. 11th Cir.).

Public Protection: Crime Victims

     FBI agents allegedly protected a group of murderers, referred to as the "Bulger gang," against apprehension and prosecution, in order to use them as informants against La Cosa Nostra. This allegedly continued for over twenty years, despite notice that the informants were killers and would continue to commit murders. The estates of three persons allegedly killed by the informants sued the FBI, FBI agents, and the informants. The U.S. government was liable for the death of a man killed after an FBI agent allegedly leaked his intent to incriminate an informant, making it foreseeable that the informant would try to murder him. The government was also liable for the deaths of an informant's former girlfriend and her daughter, because a federal agent created an unreasonable risk of harm to them by helping the informants avoid arrest. The federal agents' conduct was within the scope of their employment, given that their superiors agreed to their actions to protect the informants. The court rejected, however, claims by the decedents' families for intentional infliction of emotional distress because they lacked "contemporaneous" knowledge of the murders. An exception to liability under the Federal Tort Claims Act (FTCA), 28 U.S.C. Sec. 2671 et seq., for discretionary functions did not apply, as the conduct of the FBI was found to be criminal and in violation of the agency's guidelines. One family was awarded a total of $1,150,000, a second family received a total of $1,352,005, and a third received $219,795. Litif v. U.S., Civil Action #02-11791, 2010 U.S. Dist. Lexis 7493 (D. Mass.).

Public Protection: Motoring Public and Pedestrians

     A motorist was arrested for driving under the influence of alcohol and driving under suspension. Released from jail the following afternoon, he returned to the police station to retrieve his vehicle. Finding no "hold" on the vehicle, an officer authorized its release. The next morning, the motorist drove his vehicle while intoxication and collided with another motorist's car, resulting in the death of both drivers. The estate of the other motorist sued officers, claiming that they had breached duties to him by failing to remove license plates from his car and by releasing the vehicle to him. The plaintiff claimed that state statutes required that the vehicle be held until the intoxicated motorist's court appearance, since he had been driving on a suspended license, and that another statute required that the vehicle remain impounded because of his DUI conviction within the prior six-year period. The Ohio Supreme Court ruled that the officers could not receive summary judgment based on the "public duty rule," since the plaintiff estate claimed more than mere negligence and argued that the officers acted in a reckless and wanton manner. Estate of Graves v. City of Circleville, #2009-0014, 2010 Ohio Lexis 60.

Search and Seizure: Home/Business

     A murder suspect lived in a house with other individuals. Police received information from a friend of his that the suspect had tried to destroy evidence in a related crime, and feared that he might destroy evidence of the murder or flee. They therefore carried out an unannounced warrantless entry into the house. During the ensuing search, officers allegedly pointed guns at residents, including children, and detained them for 13 hours. A federal appeals court ruled that the officers were entitled to qualified immunity on the failure-to-announce and warrantless entry claims in the residents' lawsuit. While a jury might find that the entry was not justified by exigent circumstances, the law on the subject under these circumstances was not clearly established. Detention of the residents was justified by the dangerousness of the suspect, the need to carry out an orderly search, and the fear that evidence could be destroyed. Summary judgment was overturned, however, on excessive force claims, since a reasonable jury could find that the officers used excessive force by entering with guns drawn, pointing guns at the residents, and putting handcuffs on one of them in a manner that caused pain. Curiel v. County of Contra Costa, #07-17233, 2010 U.S. App. Lexis 1358 (Unpub. 9th Cir.).

     A private religious boarding school for children with behavioral and substance abuse problems, six former students, and thirteen parents of the former students sued Missouri juvenile officials, claiming that they conspired to raid the school and seize scores of its students. The purported ringleader of the conspiracy allegedly disliked the school because it operated, legally, without a license, because he disagreed with its teachings, and because he believed that it had not acted "very Christ-like." Juvenile authorities and armed law enforcement officers, numbering 30 persons in total, arrived at the school and removed 115 of its students, based on ex parte orders from local juvenile court judges, allegedly obtained by misrepresentations that the students were in imminent danger of physical harm and that the school was unwilling to cooperate with juvenile authorities. Because the information presented was also "stale" the raiding party lacked orders for dozens of the students that they removed, but they had orders for about forty children who no longer lived there, as well as for four adults over whom the juvenile courts lacked jurisdiction. The children were detained until their parents could pick them up, and parents were then given "stern letters" telling them to keep their children away from the school. Juvenile cases involving the children were all dismissed. The defendants were not entitled to summary judgment on the basis of qualified immunity, as the constitutional rights violated under the First, Fourth, and Fourteenth Amendment if the plaintiffs' allegations were true were clearly established. Heartland Acad. Community Church v. Anderson, #08-3723 2010 U.S. App. Lexis 2619 (8th Cir.).

     The Tennessee Supreme Court has held that the homes of parolees may be subject to a warrantless search without reasonable or individualized suspicion when searches are made a condition of parole. Officers searched the parolee's home after a pat-down search revealed that she was in possession of $975, despite the fact that she had no source of income, and after they received information that indicated that she'd "been involved in dealing drugs again." A handgun was recovered from the home during the search. The court ruled that the search did not violate either the Fourth Amendment or unreasonable search and seizure prohibitions of the state constitution. In doing so, it adopted the reasoning of the U.S. Supreme Court in Samson v. California, #04-9728, 547 U.S. 843 (2006). State of Tennessee v. Turner, #W2007-01590-SC-R11, 297 S.W.3d 155; 2009 Tenn. Lexis 678.

Search and Seizure: Search Warrant

     A married couple and their two children sued a city and one of its detectives for unlawful search, failure to "knock and announce," and excessive force. The detective, while searching for suspects in a stabbing, received information from a confidential information in which the names of a suspect and his mother were similar to the husband and wife's names. He used this information to obtain a search warrant for the plaintiffs' residence. The search was carried out by a SWAT team and a K-9 unit, who entered the home with drawn weapons. All four residents were "rounded up," but the officers then realized that they were in the wrong house. A federal appeals court found that there was sufficient evidence from which a jury could find that the search warrant was not supported by probable cause and that the detective had made representations about the location of the suspect that were either knowingly false or made with reckless disregard of the truth. As for the "knock and announce" and excessive force claims, the method with which the search had been carried out was not objectively unreasonable. Walker v. City of Wilmington, #08-4218, 2010 U.S. App. Lexis 853 (Unpub. 3rd Cir.).

Sexual Assault and Harassment

****Editor's Case Alert****

     A county sheriff hired a deputy, who was allegedly provided with little or no training. The deputy was first assigned duties as a jailer, and later as a "road deputy." During his last week on the job, after resigning to pursue a position with the state Department of Corrections, he encountered a female employee at a convenience store who asked his advice on some legal problems. She declined his offer to go on a date with him. Learning that she had several outstanding arrest warrants, and owed approximately $800 in fees and fines, he drove to the store on his last day on the job, arrested her, and transported her to the jail, telling her that he would not have done so if she had agreed to the date. At the jail, the deputy bet a jailer that he could get the arrestee to reveal her breasts. He then told the arrestee that he could get her fines reduced if she would show him her breasts, and she eventually complied. He then allegedly grabbed her exposed breast. She sued the deputy and the sheriff, claiming that the sheriff failed to properly train the deputy. The deputy was also arrested and pled guilty to second degree sexual assault. The deputy had received a policy manual, but had not been required to read it, and, in fact, did not read it. He was scheduled to attend a training academy, but had not yet attended it at the time of the incident. The trial court found the deputy liable, as well as the sheriff in his official capacity, while granting the sheriff qualified immunity in his individual capacity. A federal appeals court overturned the inadequate training liability, noting that there was no duty specified in state statutes for sheriffs to train subordinates not to sexually assault detainees, and that there had been no past pattern of such conduct by the sheriff's deputies that would have put him on notice about the need for such training. Additionally, since a reasonable officer would know that intentionally sexually assaulting a detainee was illegal, and the deputy admitted that he knew "that such conduct was impermissible," the plaintiff failed to show that the lack of training caused the assault. Parrish v. Ball, #08-3517, 2010 U.S. App. Lexis 2748 (8th Cir.).

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     Child Abuse: "Abuse, Neglect, Adoption & Foster Care Research National Incidence Study of Child Abuse and Neglect (NIS-4), 2004-2009," U.S. Dept. of Health and Human Services, Administration for Children and Families. (March 2010). A federal study indicates a decrease in serious child abuse, especially sexual abuse. An estimated 553,000 children suffered physical, sexual or emotional abuse in 2005- 06, down 26 percent from the estimated 743,200 abuse victims in 1993, according to the report. The number of sexually abused children decreased from 217,700 in 1993 to 135,300 in 2005-2006, a 38 percent drop, the study shows. The number of children who experienced physical abuse fell by 15 percent and the number of emotionally abused children dropped by 27 percent.

     Crime Victim Services: Created and successfully field-tested by eleven law enforcement agencies around the country, and offered by the International Association of Chiefs of Police (IACP), www.responsetovictims.org features 21st century approaches and effective strategies in the areas of leadership, partnering, training, and performance monitoring that place victims at the center of public safety efforts and response to crime. The site hosts four volumes of the Enhancing Law Enforcement Response to Victims Strategy and a great number of victim-related publications and materials that will assist any law enforcement agency in making significant strides towards serving this important constituency in a more comprehensive way with minimum investment. On-site and off-site technical assistance is available to agencies interested in strategy implementation.

     Dating Violence: The National Criminal Justice Reference Service (NCJRS) offers Teen Dating Violence Special Feature, an online compilation of publications and resources on the topic.

     Deadly Force: "Police Investigations of the Use of Deadly Force," by Shannon Bohrer and Robert Chaney, FBI Law Enforcement Bulletin, January 2010. "The use of force and the police investigation of such action can have far-reaching consequences."

     Technology: "Focus on In Car Camera" DVD. This no-cost resource was developed by the International Association of Chiefs of Police (IACP) Technology Technical Assistance Project (TTAP) through funding by the U.S Department of Justice, Office of Community Oriented Policing Services (COPS). This video demonstrates how planning and implementation are the keys to a successful in-car camera program that protects officers, their departments, and the citizens they serve. Free copies of the DVD may be ordered at the link.

     • Abbreviations of Law Reports, laws and agencies used in our publications.

     • AELE's list of recently-noted civil liability law resources.