Bradley Watson v. City of Marysville Ohio, 518 F. App'x 390

Watson, matching a suspect’s description, was stopped in a residential area while carrying a bag; officers warned him not to touch it.
He raised/fully opened the bag after warnings; officers warned he would be tasered if he touched it.
Watson reached into the bag; Sergeant Nicol tasered him, handcuffed him, and arrested him for obstructing official business.
State court convicted Watson of obstructing official business after finding reasonable suspicion and probable cause for detention and arrest.
Watson’s federal complaint alleges Fourth Amendment violations, plus state-law claims; district court granted summary judgment for Defendants.
On appeal, the court rejects the § 1983 challenges based on Heck, improper detention/arrest, excessive force immunity, and supervisory/municipal liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Heck bars Watson’s claims	Watson argues state court validity should not bar federal claims.	Defendants rely on Heck to bar claims that would undermine a conviction.	Heck barred; cannot collaterally attack state conviction via §1983.
Whether Watson’s unlawful arrest/detention claims survive	Detention/arrest lacked probable cause or reasonable suspicion.	State court found reasonable suspicion and probable cause for detention/arrest.	Claims barred by existing probable cause/valid detention.
Whether excessive force claim against officers is barred by qualified immunity	Watson contends excessive force was clearly established as unlawful.	No clearly established right; officers acted in questioned context with disobeying suspect.	Qualified immunity applied; no clearly established right violated.
Whether supervisory and municipal liability claims survive	City supervisors/municipality liable for training and deliberate indifference.	No underlying constitutional violation established; no supervisors’ liability.	Dismissed; no clearly established violation, no supervisory/municipal liability.
Whether civil conspiracy claim survives	Conspiracy to violate rights exists if a violation occurred.	No violation established; conspiracy claim fails.	Dismissed; no underlying violation.

Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (bar on §1983 actions that would undermine state convictions)
Mark v. Furay, 769 F.2d 1266 (7th Cir. 1985) (probable cause precludes unlawful arrest claims)
Hagans v. Franklin Cnty. Sheriff's Office, 695 F.3d 505 (6th Cir. 2012) (right to be free from taser use where compliant or non-threatening)
McQueen v. Beecher Cmty. Schs., 433 F.3d 460 (6th Cir. 2006) (supervisory liability requires unconstitutional conduct by subordinates)
City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (failure to train shows municipal liability only with deliberate indifference)
Szabla v. City of Brooklyn Park, 486 F.3d 385 (8th Cir. 2007) (en banc; constitutional rights must be clearly established for liability)