Cheri Marie Hanson v. Daniel Best, 915 F.3d 543

Officers responded to a man (Andrew Layton) found sleeping in a grocery store foyer at 4:45 a.m.; Layton awoke and resisted aggressively.
Multiple officers, private citizens, and later paramedics restrained Layton in a prone position, used knee strikes, a taser in drive-stun mode, handcuffs, a hobble, and a spit mask during transport to jail.
Paramedics evaluated Layton on scene, determined no emergency treatment was required, and prepared him for ambulance transport to the jail; officers accompanied him in the ambulance.
Upon arrival at the jail Layton went into cardiac arrest; responders restored a cardiac rhythm but he never regained consciousness and died days later; autopsy noted probable excited delirium, heart disease, liver disease, and amphetamine/alcohol use.
Layton’s mother sued the officers under 42 U.S.C. § 1983 for excessive force (Fourth Amendment) and deliberate indifference to medical needs (Fourteenth Amendment); the district court denied qualified immunity on both claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prolonged prone restraint and other force constituted excessive force under the Fourth Amendment	Hanson: Keeping Layton prone and restrained for an excessive time caused his death and violated clearly established law	Officers: Prone restraint and force were reasonable to control a resisting, possibly intoxicated/delirious subject; no clearly established rule prohibits these measures	Reversed: Right was not clearly established for prolonged prone restraint under these facts; qualified immunity applies
Whether officers were deliberately indifferent to Layton’s serious medical needs	Hanson: Layton showed signs of excited delirium; transporting him to jail rather than providing emergent care was deliberate indifference	Officers: Paramedics assessed Layton and found no emergency treatment needed; officers sought medical evaluation and stayed with him during transport	Reversed: No constitutional violation—medical professionals did not indicate emergency care was required, and officers did not deliberately disregard medical needs

Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step framework)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (clearly established law requires specificity)
White v. Pauly, 137 S. Ct. 548 (2017) (warning against high-level clearly established holdings)
Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (plaintiff must show clearly established law)
Ryan v. Armstrong, 850 F.3d 419 (8th Cir. 2017) (qualified immunity affirmed where arrestee was held prone and tased)
Henderson v. Munn, 439 F.3d 497 (8th Cir. 2006) (denial of qualified immunity where pepper-spray was used in addition to prone restraint)
Carpenter v. Gage, 686 F.3d 644 (8th Cir. 2012) (deliberate indifference standard and role of on-scene medical professionals)
De La Rosa v. White, 852 F.3d 740 (8th Cir. 2017) (describing need for a robust consensus of persuasive authority to clearly establish rights)