Bridges v. Wilson
16-5177
| 10th Cir. | Dec 4, 2017Background
- On Jan. 1, 2014, Mayes County deputy Kyle Wilson shot and killed Shane Bridges after responding to a call about an intoxicated, possibly suicidal person threatening harm to a child.
- Wilson testified Bridges stepped onto the porch, fired a shot (not at Wilson), then turned and fired toward Wilson; Wilson fired 13 shots, killing Bridges.
- The estate (Bridges’s heirs) alleged Bridges did not fire or point a gun at Wilson; witnesses (Janelle Bridges and a neighbor) said shots sounded like they came from only one gun.
- The district court, viewing the record in the estate’s favor, found genuine disputes of material fact about whether Bridges pointed/fired a gun and denied Wilson qualified immunity at summary judgment.
- Wilson appealed interlocutorily, arguing the court misapplied the facts and that the record shows Bridges pointed a gun; the appeal raised whether appellate jurisdiction exists under the collateral-order doctrine.
- The Tenth Circuit dismissed the appeal for lack of jurisdiction, explaining the appeal impermissibly asked the court to reweigh evidence and reverse the district court’s fact-sufficiency determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appellate jurisdiction over denial of qualified immunity | Estate: district court correctly found factual disputes precluding immunity | Wilson: collateral-order jurisdiction exists under §1291 because immunity denial is immediately appealable | No jurisdiction; appeal asks court to resolve fact disputes, not pure legal questions |
| Whether a jury could find Bridges did not point or fire a gun | Estate: witness testimony and circumstantial evidence support finding Bridges did not fire/point at Wilson | Wilson: ballistics and expert testimony show Bridges’s arm was raised and door evidence implies he was outside pointing at Wilson | District court reasonably found genuine fact disputes; Tenth Circuit will not second-guess these determinations |
| Whether the record "blatantly contradicts" the district court such that appellate review is permitted | Estate: record supports district court’s view; multiple bullet holes consistent with shooting through door/room | Wilson: argues ballistic paths and door testimony blatantly contradict district court | Court: record does not blatantly contradict district court; evidence is inconclusive or subject to contrary inference |
| Whether district court sufficiently articulated basis for denying summary judgment | Estate: district court explained why Wilson’s testimony could be discredited and cited witness testimony | Wilson: contends district court overlooked door/location evidence | Court: district court adequately articulated reasons; exception for vague rulings inapplicable |
Key Cases Cited
- Johnson v. Jones, 515 U.S. 304 (denial of summary judgment based on genuine factual dispute is generally not appealable)
- Mitchell v. Forsyth, 472 U.S. 511 (qualified immunity denial may be immediately appealable in limited circumstances)
- Scott v. Harris, 550 U.S. 372 (exception where record blatantly contradicts district court’s factual recitation)
- Henderson v. Glanz, 813 F.3d 938 (Tenth Circuit on appellate jurisdiction and avoiding second-guessing factual sufficiency)
- Roosevelt-Hennix v. Prickett, 717 F.3d 751 (discussion of collateral-order review for qualified immunity denials)
- Pauly v. White, 814 F.3d 1060 (addressing caution against accepting an officer’s self-serving account at summary judgment)