Amanda Smith v. R. Ray
2015 U.S. App. LEXIS 4391
| 4th Cir. | 2015Background
- Ray, a Virginia Beach police officer, encountered Amanda Smith while assisting Bullard in locating a missing juvenile at a private residence.
- Smith was on the porch; Ray had no arrest warrant and had not suspected Smith of a crime before the encounter.
- Ray suddenly grabbed Smith, threw her to the ground, kneeled on her back, and twisted her arm behind her back to handcuff her.
- Smith was compliant until grabbed; she argued and asked what Ray was doing, later claiming she was not armed and was not intoxicated.
- Ray yanked Smith by her hair after handcuffing her and a pocketknife fell from her sweatshirt; Smith suffered bruising and a broken rib.
- Smith filed a § 1983 excessive-force claim against Ray; Ray sought summary judgment based on qualified immunity, which the district court denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ray's use of force at the scene violated the Fourth Amendment | Smith | Ray | Ray not entitled to qualified immunity; force excessive |
| Whether the right was clearly established for qualified immunity at the time | Smith | Ray | Right clearly established; district court denial affirmed |
Key Cases Cited
- Waterman v. Batton, 393 F.3d 471 (4th Cir. 2005) (mention of reviewing summary judgment and favorable-view standard)
- Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-prong qualified-immunity framework)
- Tolan v. Cotton, 134 S. Ct. 1861 (U.S. 2014) (lieu of evidentiary view for reasonable-inference; deference to plaintiff)
- Graham v. Connor, 490 U.S. 386 (U.S. 1989) (objective reasonableness standard for excessive force)
- Rowland v. Perry, 41 F.3d 167 (4th Cir. 1994) (avoid segmented analysis; assess force in full context)
- Ashcroft v. al‑Kidd, 131 S. Ct. 2074 (U.S. 2011) (established-law standard need not be on-point; precedent must place question beyond debate)
- Henry v. Purnell, 652 F.3d 524 (4th Cir. 2011) (en banc; applies objective-reasonableness in Fourth Amendment excessive-force analysis)
- Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (collateral-order doctrine and immunity from suit)
- Behrens v. Pelletier, 516 U.S. 299 (U.S. 1996) (collateral-order review of qualified-immunity denials)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (permissibility of addressing prongs in different order)