Christopher Wheat v. Officer J. Day, 20-14142

Christopher Wheat, a pretrial detainee at Walton County Jail, sought to treat eczema but was denied a shower and used his cell sink, which overflowed.
After reports of flooding/commotion, five officers including Deputy Jeff Day approached Wheat’s cell; Wheat had his back to the door and was nonresistant according to Wheat.
Day tasered Wheat in the back without giving warning; Wheat was medically cleared after removal of taser prongs.
Day’s incident report said he tased Wheat in response to prior conduct (kicking the door/flooding), not an immediate threat; Wheat sued under 42 U.S.C. § 1983 for excessive force (Fourteenth Amendment).
The district court denied Day’s motion for summary judgment on qualified immunity, finding triable issues of fact and that reasonable jurors could find a constitutional violation.
The Eleventh Circuit reviewed de novo and affirmed the denial, concluding (on the record viewed in Wheat’s favor) that tasing a nonresisting pretrial detainee was excessive and that the unlawfulness was clearly established.

Issue	Wheat's Argument	Day's Argument	Held
Whether tasing Wheat violated the Fourteenth Amendment (excessive force)	Tasing was objectively unreasonable: Wheat was nonresisting, nonbelligerent, no warning or deescalation	Use of taser was justified by security concerns and Wheat’s earlier misconduct	Court: Yes — under Kingsley factors, force was disproportionate and most factors weigh for Wheat
Whether Day is entitled to qualified immunity because the right was not clearly established	Prior Eleventh Circuit precedent put officers on notice that using force on a nonresisting detainee is unlawful	Day argues no clearly established law made his conduct unlawful	Court: No qualified immunity — existing precedent gave fair warning that tasing a nonresisting detainee violates due process

Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
Kingsley v. Hendrickson, 576 U.S. 389 (objective-reasonableness test for detainees)
Piazza v. Jefferson County, 923 F.3d 947 (officers not entitled to immunity for force against nonresisting detainee)
Danley v. Allen, 540 F.3d 1298 (use of force on compliant detainee unlawful)
Hadley v. Gutierrez, 526 F.3d 1324 (punching a handcuffed suspect unlawful)
Fils v. City of Aventura, 647 F.3d 1272 (tasing a nonviolent suspect unlawful)
Coffin v. Brandau, 642 F.3d 999 (fair-warning standard for clearly established law)
Mitchell v. Forsyth, 472 U.S. 511 (collateral-order doctrine for appeals on qualified immunity)
Tinker v. Beasley, 429 F.3d 1324 (standard of review for qualified immunity denials)
Patel v. Lanier County, 969 F.3d 1173 (applying Kingsley to Fourteenth Amendment detainee claims)