Aldaba v. Marshall County, 844 F.3d 870

Johnny Leija, hospitalized for severe pneumonia and hypoxia, became agitated, removed his IV and oxygen, and behaved confused and combative; medical staff requested law-enforcement assistance to restrain him for life‑saving treatment.
Officers Pickens, Atnip, and Beebe responded, attempted verbal de‑escalation, warned Leija about Taser use, then deployed a Taser during a physical struggle so nurses could administer sedatives (Haldol and Ativan).
After the injection, Leija went limp, vomited, and despite CPR was pronounced dead; the medical examiner listed respiratory insufficiency from pneumonia exacerbated by exertion during the struggle as cause of death.
The estate sued for excessive force under the Fourth Amendment; the district court denied the officers’ summary‑judgment motion based on qualified immunity.
The Tenth Circuit originally affirmed denial of qualified immunity, but the Supreme Court’s decision in Mullenix v. Luna prompted reconsideration focused on whether the law was clearly established.
The Tenth Circuit, applying Mullenix, reversed and instructed the district court to grant summary judgment because existing precedent did not place the constitutional question “beyond debate.”

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers used excessive force in restraining Leija for medical treatment	Restraining and Tasering a non‑compliant but medically vulnerable patient constituted excessive force	Officers acted to enable life‑saving care after escalation and did not use force analogous to cases finding constitutional violations	Court did not decide whether force was excessive (remained a factual question)
Whether the law was clearly established such that qualified immunity fails	Precedent and fair‑notice principles (Hope, circuit cases) put officers on notice that their conduct violated the Fourth Amendment	Mullenix requires high specificity; no precedent "squarely governs" this fact pattern of medical restraint to permit treatment	Officers entitled to qualified immunity because no controlling precedent made violation "beyond debate"

Mullenix v. Luna, 136 S. Ct. 305 (U.S. 2015) (clarifies need for fact‑specific precedents to defeat qualified immunity in excessive‑force/chase contexts)
Brosseau v. Haugen, 543 U.S. 194 (U.S. 2004) (Fourth Amendment excessive‑force inquiry must be case‑specific)
Ashcroft v. al‑Kidd, 563 U.S. 731 (U.S. 2011) (clearly established inquiry asks whether precedent places question beyond debate)
Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (requires specificity in defining clearly established law)
Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective reasonableness standard for excessive force)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (fair‑notice principle for clearly established rights)