Asociación De Periodistas De Puerto Rico v. Mueller, 680 F.3d 70

Journalists sued FBI agents for excessive force during a 2006 search in an apartment complex in San Juan, Puerto Rico.
District court granted summary judgment on Fourth Amendment excessive force claims; prior appeal vacated a different summary judgment ruling on qualified immunity.
The operation occurred with a large, volatile crowd, no formal perimeter, and limited local police assistance.
Pepper spray and physical removal were used against reporters inside and at the gate; some plaintiffs allege punches, knocks, and lingering injuries.
Procedural disputes centered on discovery limits, use of depositions, and admissibility/authentication of video footage.
The court ultimately affirmed the district court’s summary judgment ruling on qualified immunity and denied injunctive relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discovery abuse and depositions	Plaintiffs argue district court limited discovery to harm their case.	Defendants contend limitations were appropriate to resolve immunity early.	No abuse; discretion warranted.
Video authentication and best evidence	Video evidence was improperly authenticated and violated best evidence rules.	Videos were authentic, properly authenticated, and duplicates are admissible.	Video evidence authenticated; best evidence rule satisfied.
Qualified immunity— Fourth Amendment excessive force	Agents violated clearly established Fourth Amendment rights by using excessive force.	Reasonableness of force under circumstances; immunity applies if reasonable officer would misconstrue law.	Affirmed qualified-immunity grant; force deemed reasonable.
Seizure and Fourth Amendment scope	The non-arrest seizure was constitutionally cognizable; rights were violated.	Even if seizure, actions were reasonable given the crowd and danger.	Reasonable under the circumstances; no clear-law violation.
Injunctive relief	There is a continuing risk to media coverage; injunction warranted.	No real and immediate threat of future violations; injunction improper.	Injunction denied.

Estate of Bennett v. Wainwright, 548 F.3d 155 (1st Cir. 2008) (objective reasonableness and qualified immunity protection)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-step qualified immunity framework; reasonable officer on scene)
Maldonado v. Morales, 568 F.3d 263 (1st Cir. 2009) (avoid sequential steps when facts depend on development)
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (district court may decide immunity question at any stage)
Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (state of mind and purpose limits of immunity for officials)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (agency policy relevance to fair warning of constitutional violations)
Alicea-Cardoza v. United States, 132 F.3d 1 (1st Cir. 1997) (authentication considerations for audiovisuals)
Louis Vuitton S.A. v. Spencer Handbags Corp., 765 F.2d 966 (2d Cir. 1985) (duplication copies admissible; best evidence rule practical scope)