Christian Longoria v. Pinal County
2017 U.S. App. LEXIS 19794
| 9th Cir. | 2017Background
- Manuel Longoria led a 70+ minute car chase in a stolen vehicle; Pinal County deputies (including Deputy Heath Rankin) joined after being told Longoria might be armed.
- Eloy officers ended the pursuit with a PIT maneuver; Longoria exited his disabled car surrounded by multiple officers, some of whom used beanbags and a TASER; Longoria had only a wallet or rosary beads behind his back.
- Rankin ran from a perimeter toward the collision, stopped 25–45 feet to Longoria’s right, and then fired two fatal rifle rounds into Longoria’s back just after Longoria turned, raising his empty hands above his head.
- Rankin claims he perceived a “shooter’s stance” and a weapon; other officers, Rankin’s partner Rice, a police-practices expert, and two real-time videos raise competing inferences that Longoria was unarmed and not assuming a threatening posture.
- The district court granted Rankin qualified immunity on summary judgment; the Ninth Circuit reversed, finding disputed material facts about (1) whether Longoria posed an immediate threat and (2) the reasonableness and clarity of the law, so the issues must go to a jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force / Fourth Amendment violation | Longoria: Rankin used unreasonable, deadly force against an unarmed, surrounded, and (apparently) surrendering suspect. | Rankin: He reasonably believed Longoria assumed a shooter’s stance and posed an immediate threat, justifying deadly force. | Reversed summary judgment — material factual disputes about immediacy of threat and credibility preclude resolving reasonableness as a matter of law; jury must decide. |
| Qualified immunity / clearly established right | Longoria: The right not to be shot while unarmed and nondangerous was clearly established; Rankin is not entitled to immunity given disputed facts. | Rankin: Even if a right existed, it was not clearly established as to this factual scenario; a reasonable officer could have believed deadly force lawful. | Rejected — settled law (e.g., Garner) clearly establishes that shooting an unarmed, nondangerous suspect is unlawful; disputed facts mean immunity denied at summary judgment. |
| Plaintiffs’ Rule 56(d) discovery motion | Longoria: Additional discovery was necessary to oppose summary judgment. | Defendants: District court denied the motion; summary judgment nevertheless appropriate. | Moot on appeal — remand allows further discovery. |
| Family members’ §1983 claims | Family members sought to assert their own §1983 claims for emotional harm. | Defendants argued lack of standing. | Affirmed dismissal — Fourth Amendment rights are personal; only estate may bring §1983 claim for decedent’s Fourth Amendment violation. |
| State wrongful-death claim (Arizona) | Longoria: State-law wrongful-death claim survives because fact disputes exist about reasonableness of force. | Defendants: Summary judgment should bar state claim as well. | Reversed summary judgment on state claim — factual disputes about reasonableness preclude judgment for defendants. |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
- Tennessee v. Garner, 471 U.S. 1 (police may not shoot unarmed, nondangerous suspect)
- Graham v. Connor, 490 U.S. 386 (Fourth Amendment objective reasonableness test)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law standard)
- White v. Pauly, 137 S. Ct. 548 (do not define clearly established law at high level of generality)
- Hughes v. Kisela, 862 F.3d 775 (9th Cir.) (qualified-immunity summary-judgment standards)
- Deorle v. Rutherford, 272 F.3d 1272 (9th Cir.) (consider mental illness and totality of circumstances in deadly-force analysis)
- Torres v. City of Madera, 648 F.3d 1119 (9th Cir.) (applying Garner principle)
- Cruz v. City of Anaheim, 765 F.3d 1076 (9th Cir.) (credibility disputes over perceived threat preclude summary judgment)