Brown Ex Rel. Estate of Brown v. Chapman
814 F.3d 447
| 6th Cir. | 2016Background
- On Dec. 31, 2010, Cleveland officers Chapman and Ilain stopped Rodney Brown for allegedly driving without headlights; eyewitnesses later disputed that the headlights were off. Brown was ordered out of his vehicle, frisked, and a physical confrontation followed.
- Chapman fired his taser in dart mode at Brown’s chest; Brown fled, was chased, subdued, and both officers used tasers (including drive‑stun) during the struggle. A folding knife was found in Brown’s hand.
- After being handcuffed and placed in a patrol car, Brown complained he could not breathe; officers delayed requesting EMS and Brown was later found pulseless and died.
- Shirley Brown (mother/executor) sued under 42 U.S.C. § 1983 for (inter alia) unlawful stop (no probable cause), excessive force (taser/strike), and deliberate indifference to medical needs; the City of Cleveland was also sued.
- The district court granted summary judgment in part for defendants (upholding the stop and Chapman’s taser use) and denied it in part (allowing claims for Chapman’s elbow strike and deliberate indifference against some officers). The court certified certain rulings under Rule 54(b).
- The Sixth Circuit reversed in part: it held disputed facts precluded summary judgment on the vehicle stop, Chapman’s initial taser deployment, municipal liability for taser policy/training, and deliberate‑indifference as to Officer Melendez.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of vehicle stop (probable cause) | Brown argues headlights were on; the stop lacked probable cause. | Officers contend Brown drove without headlights so stop was lawful. | Reversed summary judgment for officers — disputed facts (eyewitnesses) preclude finding probable cause. City summary judgment on this claim affirmed. |
| Chapman’s use of taser (excessive force) | Brown contends tasering a non‑threatening, non‑resisting person (after breaking away to avoid injury) was excessive. | Chapman argues Brown posed an immediate threat / resisted and taser use was reasonable. | Reversed summary judgment for Chapman — viewed in plaintiff’s favor a jury could find taser use excessive; right was clearly established. |
| Municipal liability re: taser policy and training (Monell) | City’s taser policy/training instructed center‑mass shots and used outdated materials; that policy/training caused the violation. | City argues no causal policy/custom or final‑decision ratification shown. | Reversed summary judgment for City on excessive‑force theory — jury could find policy/training was moving force and training showed deliberate indifference. Ratification theory failed (no identified final policymaker). |
| Deliberate indifference to medical needs (Officer Melendez) | Melendez heard Brown say “I can’t breathe,” observed grunting and that Brown went limp; plaintiff argues Melendez disregarded a serious medical risk. | Melendez contends circumstances (ongoing struggle) made it unreasonable to infer a serious medical condition. | Reversed summary judgment for Melendez — disputed facts permit a finding Melendez subjectively perceived and disregarded a substantial risk. |
Key Cases Cited
- Mullenix v. Luna, 136 S. Ct. 305 (2015) (qualified immunity standard; conduct must not violate clearly established rights)
- Pearson v. Callahan, 555 U.S. 223 (2009) (two‑step qualified immunity inquiry—constitutional violation and clearly established law)
- Scott v. Harris, 550 U.S. 372 (2007) (on viewing facts in light most favorable to nonmovant at summary judgment)
- Graham v. Connor, 490 U.S. 386 (1989) (objective‑reasonableness test for excessive force under the Fourth Amendment)
- Hope v. Pelzer, 536 U.S. 730 (2002) (clarifies what it means for law to be clearly established)
- Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability requires policy/practice/custom causing constitutional violation)
- City of Canton v. Harris, 489 U.S. 378 (1989) (§ 1983 training‑failure standard; deliberate indifference)
- Bryan v. MacPherson, 630 F.3d 805 (9th Cir. 2010) (description of taser effects and relevance to excessive‑force analysis)