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Assault and Battery: Chemical

     Arrestee's allegation that a police officer used mace on him after he had been handcuffed and subdued was sufficient to defeat the officer's motion to dismiss in an excessive force lawsuit, when there was no evidence that the arrestee was acting violently, posing a threat to others, or resisting arrest at the time. Hall v. Alabama Dept. of Public Safety, No. 06-15743, 2007 U.S. App. Lexis 23099 (11th Cir.).

Assault and Battery: Physical

     Reversing judgment as a matter of law for an officer in an excessive force lawsuit, a federal appeals court ruled that a jury could have concluded that the level of force used was excessive. The officer allegedly applied a pain compliance control hold on the arrestee, shoved her outside, and slammed her against a car when she was calm, sober, an compliant. The trial court did, however, correctly rule that the officer had probable cause to arrest the plaintiff for battery when she touched his badge. McIntyre v. City of San Jose, No. 05-17005, 2007 U.S. App. Lexis 25606 (9th Cir.).

     Undisputed evidence showed that a DUI arrestee was uncooperative and intoxicated and had shown that he would resist having his blood drawn at a hospital where he had been transported after his arrest. Under these circumstances, the officers had not used excessive force against him while his arms were handcuffed behind his back, and four officers were needed to subdue him. Laskey v. Legates, C.A. No. 06-18, 2007 U.S. Dist. Lexis 77586 (D. Del.).

Assault and Battery: Stun Guns/Tasers

     Police officers who came to a home in response to a 911 call reporting a disturbance there did not violate a man's rights by entering the residence, using a Taser to subdue him when they found him naked in an attic-like storage area armed with a handgun, and taking him to a hospital where he was involuntarily committed for a psychiatric evaluation. Testimony indicated that the officers believed that they were entering a home where there was a potentially violent situation and where they might need to aid a potentially injured occupant, so that the officers were entitled to qualified immunity. Nero v. Baltimore County, Md., Civil No. AMD 06-1687, 2007 U.S. Dist. Lexis 74710 (D. Md.).

Damages: Compensatory

     Motorist who was detained for allegedly producing a counterfeit driver's license, but who was released when the authenticity of the license was verified was properly awarded only $400 in damages by a jury in his federal civil rights lawsuit. While the plaintiff was in custody for two to three hours, he was never placed under arrest, and presented no medical evidence of injury. His sole evidence of damages was his wife's testimony that he was humiliated in the community by these events. Under these circumstances, the jury acted reasonably in only awarding him nominal damages, and he was not entitled to a new trial or to an award of attorneys' fees under 42 U.S.C. Sec. 1988. Chen v. City of New York, #28331/02, 2007 N.Y. Misc. Lexis 7145 (Sup. Court. Queens County).

Defenses: Statute of Limitations

     In a federal civil rights lawsuit by a woman raising various claims concerning the defendants' alleged actions impacting on her custody of a minor, allegations of abuse, and her arrest and imprisonment, all of her claims involved events occurring between 2000 and 2003. Since this time period was more than two years before the filing of her lawsuit, the trial court properly found that the lawsuit should be dismissed on the basis of a Texas statute of limitations. Morgan v. State of Texas, No. 06-20839, 2007 U.S. App. Lexis 24772 (5th Cir.).

Disability Discrimination

     When police officers reasonably believed that they were facing a potentially violent hostage situation in which an individual was in danger, they had no obligation under the Americans with Disabilities Act to provide a reasonable accommodation for an allegedly disabled mentally ill suspect.  In a previous decision, officers were held not liable for shooting and killing the suspect, who had threatened the life of an officer, and who they perceived was holding a knife and a large metal pipe with a hook at the end, and kept advancing towards them despite orders to stop and drop his weapons. Because the officers, under these exigent circumstances, had no duty to reasonably accommodate the suspect's mental illness, it was irrelevant whether or not the police department had effectively trained its officer in providing such accommodations to mentally ill hostage takers. Waller v. City of Danville, Virginia, Case No. 4:03CV00039, 2007 U.S. Dist. Lexis 73582 (W.D. Va.).

False Arrest/Imprisonment: No Warrant

     Police officer had probable cause to arrest motorist for DUI based on her "unusual and likely unlawful driving," the odor of alcohol on her breath, and her failed performance on field sobriety tests, despite the fact that the charges were later dropped when her blood alcohol level measured at below the legal limit. Ryder v. Pucillo, Civil Action No. 3-06-cv-391, 2007 U.S. Dist. Lexis 78202 (D. Conn.).

     Probable cause existed for the arrest of a man in small claims court. Witnesses testified that the arrestee was in a "highly agitated" state, made physical contact with a woman who was attempting to re-enter the line to see the court clerk, and refused to cooperate with security personnel at the court. Norasteh v. New York, No. 1864 107989, 2007 N.Y. App. Div. Lexis 10949 (1st Dept.).

     After a charge against an arrestee for interfering with police authority was dismissed, she sued for false arrest. The trial court dismissed some claims and a jury returned verdicts for the officers on remaining claims. A federal appeals court rejected the argument that the trial court was "bound" by the dismissal of the criminal charges against her by the state court. The appeals court further noted that the officer was not a party to the criminal prosecution. The trial court's decision and the jury verdicts were upheld. Barton v. City and County of Denver, No. 06-1536, 2007 U.S. App. Lexis 24940 (10th Cir.).

     Police officers acted reasonably in arresting a woman without a warrant for assaulting her daughter, based on physical evidence, the daughter's statements, and the history of violence in the family. The plaintiff also failed to state her own version of the facts in her response to the defendants' motion for summary judgment, merely denying their statement of the facts. Willette v. City of Waterville, Civil No. 06-101, 2007 U.S. Dist. Lexis 76968 (D. Maine).

     Officers had probable cause to arrest suspects as alleged accomplices in the armed robbery at a restaurant based on eyewitness identifications at a line-up and a pager number provided by one of the eyewitnesses. The fact that the arrestees were later acquitted of all charges did not alter the fact that there was probable cause for the arrests. Peet v. City of Detroit, No.05-1371, 2007 U.S. App. Lexis 22693 (6th Cir.).

False Arrest/Imprisonment: Warrant

     Police officers were not liable for arresting a suspect on the basis of an outstanding bench warrant they were informed about by a third officer when the invalidity of the warrant was not discovered until the officers and arrestee were at the police station. The warrant was not facially invalid and there was no evidence that the officers reasonably should have known that it was invalid at the time of the arrest. Hanks v. County of Delaware, No. 05-CV-6400, 2007 U.S. Dist. Lexis 73845 (E.D. Pa.).

     Four arrest warrants obtained against a suspect after he was apprehended were all based on probable cause. Additionally, no arrest warrants were actually required because officers had personally observed the suspect breaking the law. Two prosecutors and two judges sued by the arrestee had absolute immunity against the plaintiff's federal civil rights claims. Briggs v. Moore, No. 07-1918, 2007 U.S. App. Lexis 24309 (3rd Cir.).

     Arrest warrant under which arrestee was charged with assault on a police officer was adequately supported by probable cause. The application for the warrant was accompanied by an affidavit by the officer stating that the suspect had challenged him to a fight, and an affidavit by a prosecutor based on other available evidence, including an unsworn statement by another officer, which confirmed that the suspect had made the alleged challenge. Cummisky v. Mines, No. 06-5028, 2007 U.S. App. Lexis 22983 (10th Cir.).

Family Relationships

     The family of a person who died in fatal car crash failed to show that the actions of police in dealing with them following the accident violated their due process rights. No prior case recognized a due process right concerning the manner in which a family is notified of the death of a family member, and if there was any such right, it would only apply to conduct that was shocking to the conscience. In this case, the police did not act with deliberate indifference and their conduct was not conscience shocking. They did use "deception" to first obtain a photograph of the victim to aid in his identification, and did not tell the family he had died until they had made the identification. A statement the police made to the media concerning the accident was justified by the legitimate purpose of informing the public about a fatal collision. Estate of Gadway v. City of Norwich, No. 3:05-CV-935, 2007 U.S. Dist. Lexis 72561 (D. Conn.).

Firearms Related: Intentional Use

     A police officer acted reasonably within an extremely brief period of time in shooting and killing a teenage motorist whose car struck him as it drove away following a traffic stop. The officer stated that he had seen the car accelerate towards him and a "determined look" on the face of the motorist, and decided to fire upon realizing that he could not get out of the way. The officer himself testified during his deposition, that he did not know if he fired before, during, or after he was hit by the vehicle. The court found that it was reasonable to conclude that the shooting and the vehicle striking the officer happened at close to the same time. The trial court excluded offered expert witness testimony by the father of the motorist, who is a police officer, arguing that the defendant officer must have been behind the car at the time of the shooting. Hathaway v. Bazany, No. 06-50602, 2007 U.S. App. Lexis 25561 (5th Cir.).

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

     Police officers who shot and killed an allegedly suicidal suspect who approached them with a Samurai sword were not entitled to qualified immunity on the claim that they acted unreasonably in using force against him. It was argued that the officers escalated, rather than de-escalated the situation, having gone to check on his well-being, by entering his home, confronting him at the doorway to his bedroom, and using pepper spray against him, creating a situation in which deadly force was required. It was further argued that there was evidence from which it could be concluded that the decedent was trying to defend himself from the officers, who he viewed as aggressors against him. The court found that prior caselaw provided the officers with notice that it was unreasonable to aggressively confront an armed suicidal person in a threatening manner. Hastings v. Barnes, No. 04-5144, 2007 U.S. App. Lexis 24446 (10th Cir.).

     Police officer was entitled to qualified immunity in shooting a suspect during a drug raid when he feared that the suspect would take his gun as he tried to force the suspect to the ground. A federal appeals court found that an objectively reasonable officer, under the circumstances, could have believed that the suspect posed a threat, and that if he paused even for an instant he might lose his last chance to defend himself. Alford v. Cumberland County, No. 06-1569, 2007 U.S. App. Lexis 24138 (4th Cir.).

First Amendment

     Persons who were arrested and prosecuted for "open burning without a permit" after they burned a "rainbow flag" at a Gay Pride parade to express their disapproval of homosexuality, and who stated their desire to engage in similar actions in the future, had standing to pursue their claim for injunctive relief based on their claim that such conduct was protected by the First Amendment and that the process for obtaining such permits was burdensome. Daubenmire v. City of Columbus, No. 06-346, 2007 U.S. App. Lexis 25763 (6th Cir.).

     Anti-war protestor on university campus failed to show that university buildings were a designated public forum on which the school allowed the hanging of banners and "expressive painting," or that the university violated his First Amendment rights when they removed banners and painted messages he placed on the buildings to protest the war with Iraq. The court found that the university policy was clear, that there was no permission to paint messages on the sides of buildings, and that doing so was vandalism. The appeals court also rejected the plaintiff's claim that the university engaged in viewpoint discrimination in terms of which messages it removed, finding that the removal of unauthorized banners and paintings was "prioritized" on the basis of their prominence and limited by budgetary concerns. Wilson v. Johnson, No. 05-6733, 2007 U.S. App. Lexis 16568 (6th Cir.).

Governmental Liability: Policy/Custom

     A newspaper reporter died of a heart attack suffered in her home while a former sheriff was present, and her estate claimed that he had engaged in efforts to intimidate her, which caused her heart attack. These efforts were allegedly motivated by her investigation into allegations that the former sheriff engaged in campaign fraud. A settlement reached on civil rights claims were found to be enforceable against the former sheriff in his individual capacity, but not against the county of the sheriff's office. The plaintiff in the civil rights lawsuit then substituted the current county sheriff as a defendant for the former sheriff in his official capacity. A federal appeals court ruled that the county could not be held liable as there was no showing that the death of the reporter was caused by a county policy or that the former sheriff acted under color of state law. Instead, the former sheriff only acted on his own behalf. Sims v. County of Bureau, No. 01-2884, 2007 U.S. App. Lexis 24418 (7th Cir.).   

Interrogation

     A police sergeant allowed an attorney, who was also an arrestee's alibi witness, to enter an interrogation room, stated that the attorney/witness could not act as the arrestee's lawyer, and then left the room, while videotaping their conversation. The arrestee then sued the sergeant and the city for alleged violations of his Fourth and Fifth Amendment rights. A federal appeals court found that the sergeant was entitled to qualified immunity because there was no clearly established law on the subject of Fourth Amendment protection for an interrogation room conversation between a pre-trial arrestee and an attorney who was also an alibi witness. A reasonable officer, therefore, could have believed that the action of videotaping the conversation was lawful. Additionally, there was no violation of the Fifth Amendment since the conversation did not constitute an interrogation. Sowards v. City of Milpitas, No. 05-16530, 2007 U.S. App. Lexis 24583 (9th Cir.).

Negligence: Vehicle Related

     Following a jury verdict in favor of the estate of a motorist who was killed when his car was struck by a police vehicle, the city that employed the officer agreed to pay $2 million to the plaintiff. During the trial, the city and officer asserted that the motorist, an undocumented Honduran immigrant, was actually to blame for the accident, but the jury rejected that argument. Lopez v. City of Waukegan, No. 05L191, Circuit Court of Lake County, Illinois, reported in Chicago Daily Law Bulletin, pg. 3, November 5, 2007.

Police Plaintiff: Firearms Related

     In a prior decision, Curley v. Klem, #01-1093, 298 F.3d 271 (3rd Cir. 2002), a federal appeals court held that a state trooper was not entitled to qualified immunity for his shooting of a Port Authority police officer in full uniform who he stated he believed to be an armed murder suspect he had been pursuing. The injured officer claimed that trooper unreasonably failed to look into vehicle where the sought suspect had just committed suicide and unreasonably shot him only because, like the suspect, he was a "black man with a gun." Subsequently, on remand, a jury found that the shooting officer's failure to look into the window of the vehicle was unreasonable but that the officer's action in shooting the injured officer was not unreasonable. On appeal, the court found that the jury's verdict, in finding that the officer acted reasonably under the totality of the circumstances meant that no constitutional violation occurred. Curley v. Klem, No. 05-4701, 2007 U.S. App. Lexis 20213 (3rd Cir.).

Privacy

     A woman arrested following an alleged drunk-driving accident did not show that police officials and the city violated her constitutional right to privacy when they disclosed her name, hometown, photograph, phone number, and her husband's occupation (undercover officer) after the charges were brought against her. Her husband was charged with operating the vehicle while impaired, and she was charged with obstructing by lying about who was driving the car, as well as resisting. Both she and her husband pled no contest to the criminal charges. The appeals court found that criminal suspects do not have a constitutional right of privacy concerning the nondisclosure of the information the police released, including information in the police report, especially information released in response to legitimate inquiries from the press submitted under a Michigan state Freedom of Information Act. Bailey v. City of Port Huron, No. 06-2375, 2007 U.S. App. Lexis 25489 (6th Cir.).

     In a prior decision, Anderson v. Blake, No. 05-6329, 2006 U.S. App. Lexis 28144 (10th Cir.), a federal appeals court ruled that a police officer was not entitled to qualified immunity in lawsuit by rape victim claiming that he improperly released a videotape of her rape to a television station, which aired portions of it. Federal appeals court rejects officer's arguments that the victim did not have a constitutionally protected privacy interest in the contents of the tape, or that her privacy right was not clearly established. On remand, a federal trial court dismissed the plaintiff's federal right to privacy and state intrusion upon seclusion claims against the reporter and television station owner. A federal appeals court found that the plaintiff's allegations about the officer's involvement in the publication of a portion of the videotape were not sufficient to show that the officer, the reporter, and the television station owner acted jointly or that the private parties acted under color of law. Anderson v. Suiters, No. 06-6134, 2007 U.S. App. Lexis 20686 (10th Cir.).

Public Protection: Crime Victims

     City was not liable for the shooting and killing of a woman by a felon previously found by police officers to be in possession of a firearm, but not arrested at the time. The decedent's mother and estate claimed that the city's police department should be held liable because it had a policy of not arresting felons found to illegally possess weapons, but instead referring those cases to federal authorities for possible prosecution. In failing to arrest the man who subsequently shot her daughter, the plaintiff argued, the city and two of its officers created the danger that ended her life. A federal trial court ruled that there could be no liability on the basis of such an "omission claim." Mills v. City of Roanoke, Civil Action No. 7:07CV00220, 2007 U.S. Dist. Lexis 76082 (W.D. Va.).

Pursuit: Law Enforcement

     Federal ranger's actions in engaging in a high speed chase of a fleeing vehicle did not result in the U.S. government being liable under the Federal Tort Claims Act, 28 U.S.C. Sec. 1346(b)(1) for the death of a passenger in the pursued vehicle. A federal appeals court ruled that, as a matter of law, the passenger's death was caused by the behavior of the driver of the pursued vehicle and not the actions of the ranger. There was no evidence that would show that the pursuit was not necessary, that the ranger hit the fleeing vehicle, or that there was a roadblock. Additionally, because the offender sped off quickly, the ranger was unable to obtain the license plate number of the pursued vehicle, so there was no evidence that the fleeing offender could simply be apprehended at a later time. Belew v. U.S.A., No. 07-12881, 2007 U.S. App. Lexis 24461 (11th Cir.).

     Officer who allegedly did not use lights and a siren or summon assistance when engaging in the high-speed pursuit of a vehicle was not liable for injuries suffered by a passenger in a car struck by the pursued vehicle. The officer, the court found, did not create the danger that resulted in the plaintiff's injuries, and he did not engage in conduct that shocked the conscience. Rhoten v. Pase, No. 06-3346, 2007 U.S. App. Lexis 24796 (10th Cir.).

     A deputy responded to a complaint about a suspicious vehicle driving up and down a street and stopping in front of home. The deputy saw the vehicle and followed it, but lost sight of it. The following morning, a 16-year-old male was found dead from a single-vehicle accident involving a collision of his car with a utility pole at approximately 100 miles per hour. A federal appeals court ruled that the deputy's actions were legitimate law enforcement activity designed to identify a suspicious vehicle, and did not violate the youth's constitutional rights. Additionally, rejecting a state law negligence claim, the court found that there was no indication that the deputy's actions caused the youth to flee in a manner that caused the accident. O'Neal v. Cazes, No. 06-31004, 2007 U.S. App. Lexis 23011 (5th Cir.).

Search and Seizure: Home/Business

     Deputy sheriffs found drugs in the study of a home while accompanying the girlfriend of a man who lived there. The girlfriend was moving out and had gained access to the study through the use of a bolt cutter. She had summoned the officers because she thought her boyfriend had hidden some of her belongings in his locked study, and was fearful that he would return to the residence and harm her. While the search of the study was unreasonable because the girlfriend did not have authority to consent to it, the law on the subject at the time was not clearly established, and the deputies could have reasonably believed that she had authority to consent, so that they were entitled to qualified immunity. Moore v. Andreno, No. 06-3623, 2007 U.S. App. Lexis 24649 (2nd Cir.).

     A man initially convicted of rape and other crimes, and subsequently found not guilty on retrial, failed to show that his home was searched after a search warrant for the premises had expired, or that the officers exceeded the scope of the warrant when they searched a bedroom occupied by his roommate. The mere fact that the plaintiff had a roommate did not cause his home to be converted into a multi-unit building or apartment house, so that the warrant for the premises authorized the search of the entire home. Durham v. McElynn, No. 07-1857, 2007 U.S. App. Lexis 24496 (3rd Cir.).

Sexual Assault and Harassment

     Two men, now in their 40's could not pursue their claims against the City of Los Angeles and the Boy Scouts of America concerning their alleged sexual abuse by a police officer in the 1970's when they participated in a police department Explorer Scout program. Under a California statute, such claims must be brought before the victim's 26th birthday, unless the defendant knew or had reason to know of the unlawful sexual conduct by an employee or agent, and failed to take "reasonable steps, and to implement reasonable safeguards, to avoid acts of unlawful sexual conduct in the future by that person." The California Supreme Court upheld the dismissal of the lawsuit on statute of limitations grounds, finding that the plaintiffs failed to make specific enough allegations concerning the defendants' knowledge of the officer's alleged past sexual misconduct with minors to bring their case within the cited exception to the statute. Doe v. City of Los Angeles, No. S142546, 2007 Cal. Lexis 12186.

Sex Discrimination

     A man was allegedly observed and videotaped on a store's security surveillance camera masturbating in front of his girlfriend in a car outside the store. The man subsequently claimed that his right to equal protection of law was violated because he was cited for public indecency while his girlfriend was not. The appeals court rejected this claim, noting that the girlfriend cooperated with the police, and rewarding her for doing so was not improper. Sides v. City of Champaign, No. 06-1039, 496 F.3d 820 (7th Cir. 2007), rehearing denied 2007 U.S. App. Lexis 22322 (7th Cir.).

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     Special Events: Planning and Managing Security For Major Special Events: Guidelines for Law Enforcement. U.S. Department of Justice Office of Community Oriented Policing Services (COPS). For law enforcement executives, command staff, and trainers involved in, or providing training in, managing special events in their communities, the safety and security of the event itself, the people who attend the event, as well as the surrounding community, are of the utmost importance. The guide covers all aspects of pre-event planning, security needs during the event, and post-event activities. Topics covered include threat and risk assessments; intelligence; staffing needs and resources; communications; access control and credentialing; traffic and transportation; logistics, training, and public information; hazardous materials; critical infrastructure; demonstrations; and security management. Published: 10/15/2007

     Statistics: Arrest-Related Deaths in the United States, 2003-2005. Presents the first findings from the law enforcement collection of the Deaths in Custody Reporting Program (DCRP), which is the largest resource of information ever collected on arrest-related deaths. The report provides counts of all arrest-related deaths reported by State authorities in over 40 States, over a three-year period (2003-2005), by cause of death and characteristics of the deceased. It also includes all manners of death during an arrest, including homicides (both those by officers and other persons), suicides, alcohol or drug intoxication deaths, accidental injuries, and fatal medical problems. The report presents counts of deaths by cause for each State. Appendix tables provide details on the circumstances surrounding arrest-related deaths including the criminal offenses for which the arrest attempt was made; the use of weapons or other behavior by the arrest subject; and use of weapons and restraint devices by officers involved in the arrest. The report also presents comparative counts of law enforcement homicides from DCRP and counts of justifiable homicides by police, collected by the FBI’s Supplementary Homicide Reports program. Highlights include the following: Homicides by law enforcement officers made up 55% (1,095) of all deaths during arrests by State and local agencies. Eleven homicides were committed by other persons present at the scene. No other cause of death was reported half as often as homicide. Drug and alcohol intoxication accounted for 13% of all deaths, followed by suicides (12%), accidental injuries (7%), and illness or natural causes (6%). Three-quarters of the law enforcement homicides reported to DCRP involved arrests for a violent crime. Except for suicides (51%), violent offenders were involved in less than 30% of all other causes of death. Public-order offenders accounted for 8% of homicides, followed by property (4%) and drug offenders (2%). 10/07 NCJ 219534. For additional data, see Deaths in Custody Statistical Tables. Press release | Acrobat file (157K) | ASCII file (29K) | Spreadsheets (zip format 22K)

     Statistics: Crime in the United States, 2006. The FBI's annual report of U.S. crime statistics.

     Technology: Investigative Uses of Technology: Devices, Tools, and Techniques by the National Institute of Justice October 2007. This NIJ special report discusses techniques and resources for investigating technology-related crime. It explains technology-related tools and devices that an investigator may encounter or that may assist an investigation, and legal issues affecting the use of high technology. Devices not only can aid an investigation; they can facilitate crime. For example, criminals can use cell phones to trigger explosives and credit cards and other customer cards to engage in fraud, theft, and identity theft. For each device described, the report provides an overview of their functions and usefulness to investigators. Devices can be multifunctional (e.g., cell phones can perform camera functions). As more functions converge into a single device, investigators need to be aware that relevant information can be stored in seemingly mundane or commonplace objects or devices.

     Terrorism, Homeland Security, and National Security Issues: Law Enforcement Intelligence: A Guide for State, Local, and Tribal Law Enforcement Agencies. U.S. Department of Justice Office of Community Oriented Policing Services (COPS). This intelligence guide was prepared in response to requests from law enforcement executives for guidance on intelligence functions in a post-September 11 world. It will help law enforcement agencies develop or enhance their intelligence capacity and enable them to fight terrorism and other crimes while preserving community policing relationships. Published: 09/24/2007

     Terrorism, Homeland Security, and National Security Issues: National Strategy for Information Sharing. On October 31, 2007, the White House announced the release of the National Strategy for Information Sharing. The Strategy sets forth a plan to build upon the progress made in improving information sharing since the September 11 attacks and establishes an integrated national information sharing capability. It was developed using a collaborative process and based on significant input provided by members of the Federal Information Sharing Council, as well as state, local, tribal, and private sector officials from across the nation.

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

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