Christopher Cantu v. City of Dothan, Alabama
974 F.3d 1217
| 11th Cir. | 2020Background
- On Dec. 30, 2014, Robert Lawrence found a stray dog and drove to the Dothan Animal Shelter; a shelter employee asked for ID and intake forms, Lawrence refused, and an argument ensued.
- Sergeant Adrianne Woodruff followed Lawrence to his car, learned there was a firearm in the vehicle, and detained him while waiting for backup; dashcam and bystander phone videos recorded the encounter up to the fatal shot.
- Officer Rhodes and Officer Skipper arrived; a physical struggle followed as officers attempted to handcuff Lawrence; Rhodes used a taser (prong mode ineffective due to clothing) and Woodruff then used the taser in drive-stun mode at least twice.
- During the struggle over the taser, there is disputed video and testimonial evidence about who controlled the taser; within seconds Woodruff drew her service weapon and, without giving any warning, shot Lawrence; he later died.
- The executor sued under 42 U.S.C. § 1983 (Fourth Amendment excessive force) and for state assault/battery; the district court granted summary judgment to Woodruff (including qualified immunity and state-agent immunity), and the Eleventh Circuit reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Woodruff used excessive deadly force in violation of the Fourth Amendment | Lawrence was non-violent, resisting but not posing a serious threat; taser was in drive-stun mode and unlikely to incapacitate; Woodruff shot without warning | Woodruff reasonably believed Lawrence had or was gaining control of the taser, could incapacitate an officer and seize a firearm, justifying immediate deadly force | Viewing evidence in plaintiff's favor, a genuine dispute exists and a reasonable jury could find the shooting unreasonable; summary judgment on no-violation theory was improper |
| Qualified immunity — was the unlawfulness of the shooting "clearly established"? | The shooting was so obviously excessive that any reasonable officer would know it was unlawful (obvious-clarity exception) | No controlling, materially similar precedent existed; a reasonable officer could disagree given the rapidly evolving threat | The court concluded the violation was clearly established under the obvious-clarity doctrine; Woodruff not entitled to qualified immunity at summary judgment |
| State-agent immunity for assault and battery under Alabama law | Because a constitutional violation is plausibly shown and the act was beyond authority/willful, state immunity is lost | Woodruff acted in discretionary function and is entitled to immunity | Paralleling the qualified-immunity analysis, a jury could find she acted beyond authority; state-agent immunity not resolved for summary judgment |
| Whether officers had probable cause / reasonable belief of imminent serious harm justifying deadly force | Misdemeanor basis for detention; three officers present; taser in drive-stun unlikely to incapacitate; no warning given | Officer could reasonably believe taser control would lead to incapacitation and seizure of firearm, posing imminent danger | There is a material factual dispute about the immediacy and severity of the threat; resolution must await the jury |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive-force Fourth Amendment claims)
- Tennessee v. Garner, 471 U.S. 1 (1985) (deadly-force use and the role of warnings when feasible)
- Brosseau v. Haugen, 543 U.S. 194 (2004) (qualified immunity in excessive-force contexts)
- Hope v. Pelzer, 536 U.S. 730 (2002) (obvious-clarity exception to qualified immunity where unlawfulness is readily apparent)
- Oliver v. Fiorino, 586 F.3d 898 (11th Cir. 2009) (repeated tasing of nonthreatening person was excessive; invoked obvious-clarity)
- Mercado v. City of Orlando, 407 F.3d 1152 (11th Cir. 2005) (shooting a nonthreatening, compliant person can be obviously unconstitutional)
- Fils v. City of Aventura, 647 F.3d 1272 (11th Cir. 2011) (taser generally not a deadly weapon; limits on drive-stun/prong uses)
- Shaw v. City of Selma, 884 F.3d 1093 (11th Cir. 2018) (deadly force may be reasonable when officer reasonably perceives a threat despite other Graham factors)