Chris Blosser v. Todd Gilbert, 422 F. App'x 453

Blosser engaged in a high-speed chase after unlawfully driving away with a vehicle and evading officers.
Officers Gilbert and Carpentier pulled Blosser through his truck window during the confrontation.
Blosser sustained a tear in the long-head of the left biceps tendon; emergency room prescribed care and a follow-up orthopedic appointment.
Blosser alleged delayed and inadequate medical care while in jail, leading to his § 1983 claims against the officers and Lloyd.
District court granted summary judgment to all defendants on qualified immunity and Eighth Amendment grounds; Blosser appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officers were entitled to qualified immunity on the excessive-force claim	Blosser argues force was unreasonable given the removal through the window.	Gilbert and Carpentier contend removal was reasonable under Graham and Dunn.	Yes; officers entitled to qualified immunity
Whether removal through the window violated Blosser's Fourth Amendment rights	Removal through the window was per se unlawful excessive force.	Court should follow Dunn and find reasonableness under the circumstances.	Not clearly established; qualified immunity applies
Whether the handcuffing of Blosser constituted excessive force	Handcuffing behind the back in the presence of injury could be excessive.	Handcuffing was reasonable given the overall restraint and risk.	Objectively reasonable; no excessive-force violation
Whether Lloyd engaged in deliberate indifference to Blosser's medical needs	Delay in orthopedic treatment caused ongoing harm and should have been treated as a serious medical need.	Delay did not create a serious medical need or prove deliberate indifference.	No serious medical need shown; claim fails

Dunn v. Matatall, 549 F.3d 348 (6th Cir. 2008) (officers may remove a suspect from a car after evasion where reasonable)
Graham v. Connor, 490 U.S. 386 (1989) (relevance of severity, immediate threat, and resistance to force used)
Saucier v. Katz, 533 U.S. 194 (2001) (qualified immunity framework; border between excessive and acceptable force)
Pearson v. Callahan, 129 S. Ct. 808 (2009) (district court may address the two prongs of qualified immunity in any order)
Lyons v. City of Xenia, 417 F.3d 565 (6th Cir. 2005) (clarity of the right must be sufficiently clear for qualified immunity)
Brosseau v. Haugen, 543 U.S. 194 (2004) (clear notice of illegality required for qualified immunity)
Graham v. DeSoto, 489 F.3d 227 (6th Cir. 2007) (factor-based analysis for objective reasonableness of force)
Blackmore v. Kalamazoo Cnty., 390 F.3d 890 (6th Cir. 2004) (obvious medical-need standard for serious injury)
Napier v. Madison Cnty., 238 F.3d 739 (6th Cir. 2001) (effect-of-delay standard for delayed medical treatment)
Johnson v. Karnes, 398 F.3d 868 (6th Cir. 2005) (obviousness standard and multiple standards for serious medical needs)
Dixon v. Donald, 291 F. App’x 759 (6th Cir. 2008) (handcuffing and medical-related claims considerations)