Stanfield v. City of Lima

Case Citation: Stanfield v. City of Lima, Fed. Appx. (6th Cir. 2018)
Holding: The Court of Appeals Sixth Circuit Judge held that the police officer’s act of performing a “takedown” of arrestee was objectively unreasonable, and thus violated arrestee’s constitutional rights. However, the police officer was entitled to qualified immunity on arrestee’s excessive force claim.
Judgment: AFFIRMED.
Fact Background: On October 4, 2013, after receiving reports that a white RV was driving erratically in the area, Lima located, followed, and pulled over a white RV being driven by an elderly man, William Stanfield. A dashcam and two body microphones recorded the events that then ensued. Stanfield was “tripped and taken to the ground by one officer, kneed repeatedly in the ribs by another officer, and struck twice in the legs with a long flashlight by a third officer,” because he failed to show his hands quickly enough while on the ground. Stanfield was taken to the hospital where medical staff identified swelling and redness on his eye and face as well as many fractures in his ribs.
Procedural Background: Stanfield sued the three officers for excessive use of force in violation of 42 U.S.C. 1983 statute as well as the chief of police and the City of Lima, Ohio for “deficient hiring and supervision of the three officers.” The district court granted defendants qualified immunity and motion for summary judgement. Stanfield appealed.
Opinion: The Sixth Circuit AFFIRMED the district court’s holding that the police officer’s act of performing a “takedown” of arrestee was objectively unreasonable, and thus violated arrestee’s constitutional rights. The Court does not believe the officers reasonably feared “Stanfield was armed and reaching for a weapon, as might pose a significant threat of violence and warrant a severe physical response. Further, at the time of the arrest, Stanfield was 68 years old and heavily intoxicated. As such, he did not appear to pose much of a threat to the safety of three much younger officers, nor did he pose a reasonable threat of fleeing.” Based on the undisputed facts of the case, particularly in the evidence that officers did not believe Plaintiff was carrying a gun, the Court determined that Defendants’ use of force was excessive and unconstitutional. The Court writes:

A reasonable officer would have concluded both that Stanfield posed no real threat and that his ambiguous resistance did not justify an aggressive tackle without warning. In this Court’s view, Montgomery unnecessarily escalated a non-violent situation, resulting in the use of severe force against Stanfield. Thus, this Court concludes Montgomery violated Stanfield’s constitutional rights.

Stanfield v. City of Lima, Fed. Appx. (6th Cir. 2018)

Despite affirming the unconstitutionality of Defendants’ use of force, the Court AFFIRMED the district court’s decision to grant Defendant qualified immunity because “the law governing these circumstances is sufficiently unclear.” The Court explains:

In the excessive force context, it is not enough that a plaintiff establishes that the defendant’s use of force was excessive under the Fourth Amendment. To defeat qualified immunity, the plaintiff must show that the defendant had notice that the manner in which the force was used had been previously proscribed … The parties have not cited, nor is this Court aware of, any published case in this Circuit that clearly proscribes the tackling of a suspected drunk driver who refused to comply with officers’ instructions and pulls away from them during an attempted pat-down.

Stanfield v. City of Lima, Fed. Appx. (6th Cir. 2018)

In essence, the plaintiffs have not presented any cases placing the constitutionality of Defendants conduct completely “beyond debate” as no other cases have facts similar enough to the facts of the case at hand. Thus, “while this Court does not approve of Montgomery’s treatment of Stanfield, Montgomery is nonetheless entitled to qualified immunity.”
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