Lincoln v. Turner

Case Citation: Lincoln v. Turner, 874 F.3d 833 (5th Cir. 2017)
Holding: Although Plaintiff adequately alleged claims under Fourth Amendment for unreasonable seizure and excessive force, detaining officer was entitled to qualified immunity because it was not clearly established that officer needed probable cause to detain plaintiff or that force used in plaintiff’s particular situation was clearly unreasonable.
Judgment: AFFIRMED.
Fact Background: On December 26, 2013, John Lincoln—diagnosed with bipolar disorder and out of medication—went to his mother’s house with a gun. The only person home, however, was his then-eighteen-year-old daughter Erin Lincoln. John’s sister called the police and told them John might pose a threat to his mother (who wasn’t actually home). A large SWAT team arrived, and Erin told a police dispatcher that her father would not hurt her. John began opening the front door and shouting while holding the gun, and the police eventually shot and killed him, with Erin standing next to him. After she fell to the ground and cried out, she was seized and handcuffed by Officer Patrick Turner, who threw her over his shoulder, carried her to the backyard, hung over the back gate, and then kept in the back of a police car—still handcuffed—for two hours. She was later taken to the police station and interrogated for another five hours.
Procedural Background: Witness to police officers’ shooting of her father, Erin Lincoln, brought a civil rights suit against Turner and others under section 1983, alleging unreasonable seizure and excessive force in violation of the Fourth Amendment. The district court granted qualified immunity and motion to dismiss to the officers. Witness, Erin Lincoln, appealed.
Opinion: The Court determined that Plaintiff adequately alleged claims under Fourth Amendment for unreasonable seizure and excessive force. In an opinion by Circuit Judge Patrick E. Higginbotham, it was determined that “the facts as alleged in the amended complaint do not permit a conclusion that [Turner] had probable cause to arrest [Erin][for interference] at the time of the arrest[]” and that “the ‘factual content’ pled ‘allows the court to draw the reasonable inference that the defendant is liable for’ an unconstitutional arrest.” In summary, the Court concluded that, “accepting Erin’s allegations as true, Turner lacked the ‘minimal level of objective justification’ to detain her.” Thus, Erin adequately pled her claim that Turner’s actions were unreasonable and in violation of her Fourth Amendment constitutional right against excessive force and unreasonable seizure. Despite several prior relevant cases noticing Turner that his use of excessive force in detaining a witness to her father’s death, particularly in the manner he detained her, the court said that “none of those cases clearly established that a law enforcement officer could not detain a witness to a police shooting for these two hours while a SWAT team sorted out the scene, at the least when the witness was standing beside a person when the police shot him.” In other words, there wasn’t any Fifth Circuit case with functionally identical facts. Judge Higginbotham writes:

Plaintiffs have not cited any authority to establish that every reasonable officer would have known that he could not detain a witness for a period of approximately two hours while an investigation was underway, nor have they shown that Turner’s actions in removing Erin from the area where medical personnel were treating her injured father was clearly unreasonable and that every officer would have known so.

Lincoln v. Turner, 874 F.3d 833 (5th Cir. 2017)

Although Erin adequately pled her Fourth Amendment claims, the facts of the case do not mirror the exact facts and contexts of the supporting caselaw. Thus, the Court determined there was no “clearly established law” rendering the violent detaining of a witness for two hours unconstitutional. On that basis, the Court AFFIRMED the district court motion to dismiss and order granting Defendants qualified immunity against further suit and damages.
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