Bryce Masters v. Timothy Runnels, 998 F.3d 827

On Sept. 14, 2014, Officer Timothy Runnels stopped 17‑year‑old Bryce Masters for a license‑plate warrant error, ordered him out of the car, and never requested identification or explained the stop.
Runnels initially fired an X26 Taser in probe mode; he then continuously held the trigger for at least 20 seconds (four cycles). Masters complied during the last ~15 seconds and fell unconscious shortly after, suffering cardiac arrest and anoxic brain injury.
After handcuffing the unconscious Masters, Runnels lifted and dropped him face‑first onto concrete, fracturing teeth and causing facial injuries.
Masters sued under 42 U.S.C. § 1983 for excessive force (firing the Taser, prolonged tasing, and the drop). A jury found for Masters on the prolonged‑Taser and drop claims, awarding large compensatory and punitive damages.
The district court denied Runnels’s qualified‑immunity JMOL and motions to exclude two experts (a vocational rehabilitationist and an economist), but granted remittitur reducing punitive damages for the drop claim; Runnels appealed and Masters cross‑appealed the remittitur.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of JMOL based on qualified immunity for prolonged Taser discharge was erroneous	Masters: prolonged tasing of a now‑compliant, nonviolent misdemeanant was excessive force	Runnels: encounter was tense/rapidly evolving; continued discharge was reasonable to subdue until fully secured	Affirmed: jury reasonably found excessive force; qualified immunity denied because law was clearly established prohibiting prolonged tasing of nonresisting suspects
Whether district court abused discretion admitting Dreiling (vocational) and Dr. Tabak (economics) expert testimony	Masters: experts relied on medical records, testing, interviews, and expertise to opine on diminished earning capacity	Runnels: Dreiling impermissibly opined beyond medical evidence; Tabak relied improperly on Dreiling	Affirmed: experts’ methods and bases were admissible; challenges went to weight, not admissibility
Whether remittitur reducing punitive damages for the drop claim was proper	Masters: original punitive award justified by reprehensibility of drop; court’s remittitur was too large	Runnels: punitive award was excessive and district court’s reduction was warranted	Reversed in part: appellate court found district court’s remittitur insufficiently reflective of misconduct; remanded to enter $425,700 punitive damages (9:1 ratio to compensatory award)

Graham v. Connor, 490 U.S. 386 (1989) (objective‑reasonableness test for Fourth Amendment excessive‑force claims)
Jackson v. Stair, 944 F.3d 704 (8th Cir. 2019) (prolonged or repeated tasing of a non‑threatening, non‑resisting suspect can be excessive force; law clearly established)
Shekleton v. Eichenberger, 677 F.3d 361 (8th Cir. 2012) (use‑of‑force factors: crime severity, threat posed, active resistance)
Brown v. City of Golden Valley, 574 F.3d 491 (8th Cir. 2009) (qualified immunity framework and reasonableness standard)
Quigley v. Winter, 598 F.3d 938 (8th Cir. 2010) (approach for proportionality of punitive damages; 9:1 ratio discussion)
BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996) (guideposts for assessing grossly excessive punitive damages)
State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (due‑process limits on punitive‑to‑compensatory ratios)