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The U.S. Supreme Court has mandated a two-step sequence for resolving government officials' qualified immunity claims. A court must determine (1) whether the facts that a plaintiff has alleged make out a violation of a constitutional right and (2) whether the right at issue was "clearly established" at the time of the defendant's alleged misconduct. A right may be clearly established without a case directly on point, but existing precedent must have placed the statutory or constitutional question beyond debate. In the excessive force context, a constitutional violation is clearly established if no reasonable officer could believe the act was lawful. Courts are permitted to exercise their sound discretion in deciding which of the two prongs of the qualified immunity analysis should be addressed first in light of the circumstances in the particular case at hand. However, deciding the two prongs in order is often beneficial.
Fort Worth Police Officers W.F. Snow and Javier Romero arrested Jermaine Darden, a black man who was obese, while executing a no-knock warrant at a private residence. In arresting Darden, the officers allegedly threw him to the ground, tased him twice, choked him, punched and kicked him in the face, pushed him into a face-down position, pressed his face into the ground, and pulled his hands behind his back to handcuff him. Darden suffered a heart attack and died during the arrest. The administrator of Darden's estate subsequently brought the present 42 U.S.C. § 1983, claiming that the officers used excessive force in arresting Darden and that the City was liable for failing to adequately train the officers. All of the defendants filed motions for summary judgment, and the district court granted their motions and dismissed the case. The district court determined that the officers had not violated clearly established law and were thus entitled to qualified immunity. In addition, the district court stated that the plaintiff had failed to show that Darden's death resulted only from the officers' use of force. Because it held that the officers had not violated Darden's constitutional rights, the district court likewise dismissed the municipal liability claims. The present appeal followed.
Did the defendant officers follow clearly established rules in arresting Darden, thereby entitling them to qualified immunity, and justifying the grant of summary judgment in their favor?
The court held that the district court erred in finding that an excessive force claim could not arise from Darden’s death during the officers' execution of a no-knock warrant because Darden had preexisting medical conditions, as the evidence suggested that Darden would not have suffered a heart attack and died if the officers had not tased him, forced him onto his stomach, and applied pressure to his back. According to the court, a jury could find that Darden did not pose an immediate threat to the officers' safety and that he was trying to get into a position where he could breathe and was not resisting arrest. The court further held that the officer who allegedly tased Darden and an officer who allegedly choked, kicked, and punched Darden were not entitled to qualified immunity because a jury could conclude that Darden was not actively resisting.