Christopher Lankford v. City of Plumerville, Arkansas, 42 F.4th 918

Lankford fled from police on a motorcycle at speeds over 100 mph, weaving through traffic and crossing into oncoming lanes during an over-three-minute pursuit captured on dashcam.
Morrilton officers requested assistance as the chase approached Plumerville; dispatch told Plumerville Assistant Chief Albert Duvall that the motorcycle was coming toward town on Highway 64 and asked to “shut it off towards the interstate.”
Duvall, the only Plumerville officer on duty, drove to the town outskirts with lights/sirens and positioned his SUV as a roadblock on Highway 64; parties dispute whether it was angled or perpendicular and whether Duvall moved the SUV immediately before impact.
Lankford made no effort to stop, collided with Duvall’s SUV, was ejected and severely injured; he admitted possible intoxication that day.
Lankford sued under 42 U.S.C. § 1983 for excessive force (Fourth/Fourteenth Amendments). The district court granted summary judgment to the City and Duvall; the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Duvall’s roadblock/collision constituted unreasonable (deadly) force	Duvall used excessive/deadly force by blocking/engineering collision	Lankford’s conduct created a deadly risk to officers and bystanders; terminating the chase was reasonable	Use of force was reasonable; summary judgment for defendants affirmed
Whether Duvall had probable cause to believe Lankford posed a serious threat	Duvall lacked detailed knowledge of the chase and threat level	Dispatch reported a >100 mph chase toward a populated town; Duvall was the last line of defense	Information known to Duvall was sufficient to establish probable cause
Whether Duvall could reasonably rely on dispatch/other officers’ requests for a roadblock	Dispatcher did not expressly authorize a perpendicular block; Morrilton intended a different tactic	Duvall reasonably relied on dispatch and fellow officers in a tense, time-sensitive situation	Reliance on dispatch/fellow officers was reasonable under the circumstances
Whether the SUV was hidden or Duvall engineered the collision (comparisons to Hawkins)	SUV was in a shadow and Duvall moved forward to cause impact, making this like Hawkins	Dashcam shows flashing lights visible seconds before impact and Lankford had opportunity to slow; even a last-second move was a split-second tactical decision	Video evidence undermines Lankford’s visibility claim; even if moved, the action was reasonable and not like Hawkins

Graham v. Connor, 490 U.S. 386 (establishes Fourth Amendment objective-reasonableness test for excessive force)
Scott v. Harris, 550 U.S. 372 (officer may end dangerous high-speed chase even if it risks serious injury to fleeing motorist)
Plumhoff v. Rickard, 572 U.S. 765 (use of force reasonable to stop a high-speed, prolonged, dangerous pursuit)
Mullenix v. Luna, 577 U.S. 7 (no Supreme Court finding that deadly force in dangerous car chases violates the Fourth Amendment)
Cole v. Bone, 993 F.2d 1328 (8th Cir. – deadly force justified in high-speed, dangerous vehicle flight)
Thompson v. Dill, 930 F.3d 1008 (8th Cir. – deadly force reasonable where suspect poses threat of serious physical harm)
Estate of Morgan v. Cook, 686 F.3d 494 (8th Cir. – factors for evaluating seizure reasonableness)
Hawkins v. City of Farmington, 189 F.3d 695 (8th Cir. – contrasted case where officer’s maneuvering could support unreasonable-force verdict)