City of Escondido v. Emmons, 139 S. Ct. 500

In April–May 2013 Escondido police responded to reports of domestic disturbances at Maggie Emmons’ apartment; officers previously took a report and arrested her husband weeks earlier.
On May 27, a 911 caller (Ametria Douglas’ mother) reported hearing yelling and a daughter screaming for help; dispatch told officers two children might be inside and calls to the apartment had gone unanswered.
Officers knocked, spoke through a window, and attempted a welfare check; a man inside told Emmons to step back from the window.
When a man opened the apartment door and attempted to leave, Officer Craig told him not to close the door; the man closed it and tried to pass Craig, who took him to the ground and handcuffed him without visible injury.
The man was arrested for misdemeanor resisting/delay; he was Marty Emmons (plaintiff), who sued under 42 U.S.C. § 1983 alleging excessive force.
District Court granted summary judgment to officers (finding no excessive force and qualified immunity); Ninth Circuit reversed and remanded as to both officers; Supreme Court reversed as to Sergeant Toth and vacated/remanded as to Officer Craig for further qualified-immunity analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers used excessive force in effectuating arrest	Emmons: Craig used unlawful force in takedown/handcuffing as he exited apartment	Officers: takedown was reasonable given safety concerns and possible danger inside; only minimal force used	District Court: no excessive force; Ninth Circuit reinstated claim; Supreme Court remanded for proper analysis as to Craig and reversed reinstatement as to Toth
Whether clearly established law prohibited the officers’ conduct (qualified immunity)	Emmons: right to be free from excessive force was clearly established and applies here	Officers: no controlling precedent placing the unlawfulness of the takedown beyond debate; reasonable officer could believe force lawful	Supreme Court: Ninth Circuit defined the right too generally; remanded to analyze whether precedent clearly forbade Craig’s specific conduct; reversed as to Toth for lack of explanation

Kisela v. Hughes, 584 U.S. _ (qualified immunity standard; specificity required for clearly established rights)
District of Columbia v. Wesby, 583 U.S. _ (existing precedent must place unlawfulness of officer’s action beyond debate)
White v. Pauly, 580 U.S. _ (need for case-specific clearly established law in excessive-force contexts)
Mullenix v. Luna, 577 U.S. _ (qualified immunity principles applied to use-of-force claims)
Gravelet-Blondin v. Shelton, 728 F.3d 1086 (9th Cir.) (discusses non-trivial force against passive resistance; relied on by Ninth Circuit)
City and County of San Francisco v. Sheehan, 575 U.S. _ (whether circuit precedent can clearly establish law)